A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S....

655
State of Ohio Environmental Protection Agency STREET ADDRESS: MAILING ADDRESS: Lazarus Government Center 50 W. Town St., Suite 700 Columbus, Ohio 43215 TELE: (614) 644-3020 FAX: (614) 644-3184 www.epa.state.oh.us P.O. Box 1049 Columbus, OH 43216-1049 1/8/2009 Pamela Blakley Via E-Mail Notification United States Environmental Protection Agency Mail Code: AR-18J 77 West Jackson Blvd. Chicago, IL 60604-3507 RE: PROPOSED AIR POLLUTION TITLE V PERMIT Facility Name: American Trim L.L.C. Facility ID: 0575010106 Permit Type: Initial Permit Number: P0088868 Dear Ms. Coburn: A proposed OAC Chapter 3745-77 Title V permit for the referenced facility has been issued for review by U.S. EPA. This permit has been posted to the Division of Air Pollution Control (DAPC) Web page http://www.epa.state.oh.us/dapc in Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance as a final action not less than 45 days from the date of this letter. Please contact me at (614) 644- 3631 by the end of the 45 day review period if you wish to object to the proposed permit. Sincerely, Michael W. Ahern, Manager Permit Issuance and Data Management Section, DAPC Cc: Ohio EPA DAPC, Southwest District Office Ted Strickland, Governor Lee Fisher, Lieutenant Governor Chris Korleski, Director v Printed on Recycled Paper Ohio EPA is an Equal Opportunity Employer Printed in-house

Transcript of A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S....

Page 1: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencySTREET ADDRESS: MAILING ADDRESS:

Lazarus Government Center50 W. Town St., Suite 700Columbus, Ohio 43215

TELE: (614) 644-3020 FAX: (614) 644-3184www.epa.state.oh.us

P.O. Box 1049Columbus, OH 43216-1049

1/8/2009

Pamela Blakley Via E-Mail NotificationUnited States Environmental Protection AgencyMail Code: AR-18J77 West Jackson Blvd.Chicago, IL 60604-3507

RE: PROPOSED AIR POLLUTION TITLE V PERMITFacility Name: American Trim L.L.C.Facility ID: 0575010106Permit Type: InitialPermit Number: P0088868

Dear Ms. Coburn:

A proposed OAC Chapter 3745-77 Title V permit for the referenced facility has been issued for review by U.S. EPA. This permit has been posted to the Division of Air Pollution Control (DAPC) Web page http://www.epa.state.oh.us/dapc in Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance as a final action not less than 45 days from the date of this letter. Please contact me at (614) 644-3631 by the end of the 45 day review period if you wish to object to the proposed permit.

Sincerely,

Michael W. Ahern, ManagerPermit Issuance and Data Management Section, DAPC

Cc: Ohio EPA DAPC, Southwest District Office

Ted Strickland, GovernorLee Fisher, Lieutenant Governor

Chris Korleski, Director

v Printed on Recycled PaperOhio EPA is an Equal Opportunity Employer Printed in-house

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

PROPOSED

Air Pollution Title V Permitfor

American Trim L.L.C.

Facility ID: 0575010106Permit Number: P0088868Permit Type: InitialIssued: 1/8/2009Effective: To be entered upon final issuanceExpiration: To be entered upon final issuance

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Air Pollution Title V Permit for

American Trim L.L.C.Table of ContentsAuthorization.........................................................................................................................................................1

A. Standard Terms and Conditions......................................................................................................................21. Federally Enforceable Standard Terms and Conditions............................................................................3

2. Monitoring and Related Record Keeping and Reporting Requirements.....................................................33. Scheduled Maintenance..............................................................................................................................6

4. Risk Management Plans.............................................................................................................................65. Title IV Provisions........................................................................................................................................6

6. Severability Clause......................................................................................................................................77. General Requirements................................................................................................................................7

8. Fees............................................................................................................................................................89. Marketable Permit Programs.......................................................................................................................8

10. Reasonably Anticipated Operating Scenarios...........................................................................................811. Reopening for Cause................................................................................................................................8

12. Federal and State Enforceability...............................................................................................................913. Compliance Requirements........................................................................................................................9

14. Permit Shield...........................................................................................................................................1015. Operational Flexibility..............................................................................................................................10

16. Emergencies...........................................................................................................................................1117. Off-Permit Changes.................................................................................................................................11

18. Compliance Method Requirements.........................................................................................................1219. Insignificant Activities or Emissions Levels.............................................................................................12

20. Permit to Install Requirement..................................................................................................................1221. Air Pollution Nuisance.............................................................................................................................12

22. Permanent Shutdown of an Emissions Unit............................................................................................1223. Title VI Provisions....................................................................................................................................13

24. Reporting Requirements Related to Monitoring and Record Keeping Requirements Under State Law Only.........................................................................................................................................................13

25. Records Retention Requirements Under State Law Only.......................................................................1326. Inspections and Information Requests....................................................................................................13

27. Scheduled Maintenance/Malfunction Reporting......................................................................................1428. Permit Transfers......................................................................................................................................14

29. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations....................14

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State of Ohio Environmental Protection AgencyDivision of Air Pollution ControlB. Facility-Wide Terms and Conditions..............................................................................................................16

C. Emissions Unit Terms and Conditions..........................................................................................................181. B001, Bumper 200 AMU.........................................................................................................................19

2. K005, Coating/Printing Press C-5...........................................................................................................223. K006, Coating/Printing Press C-4...........................................................................................................30

4. K007, Coating/Printing Press C-3...........................................................................................................385. K008, Coating/Printing Press C-2...........................................................................................................46

6. K009, Coating/Printing Press C-1...........................................................................................................537. K022, A-Line Screen Presses.................................................................................................................60

8. K033, B-Line Screen Presses.................................................................................................................699. K045, Roll Coater; Department 347........................................................................................................78

10. K046, E-coat Line....................................................................................................................................8711. K048, Dept 350........................................................................................................................................94

12. P081, Stamping Press 1-269................................................................................................................10313. P082, Stamping Press 1-082................................................................................................................109

14. P085, Stamping Press 1-213................................................................................................................11515. P086, Stamping Press 1-247................................................................................................................121

16. P087, Stamping Press 1-087................................................................................................................12717. P088, Stamping Press 1-088................................................................................................................133

18. P089, Stamping Press 1-248................................................................................................................13919. P090, Stamping Press 1-249................................................................................................................145

20. P091, Stamping Press 1-091................................................................................................................15121. P092, Stamping Press 1-251................................................................................................................157

22. P093, Stamping Press 1-252................................................................................................................16323. P094, Stamping Press 1-253................................................................................................................169

24. P095, Stamping Press 1-272................................................................................................................17525. P096, Stamping Press 1- 276...............................................................................................................181

26. P097, Stamping Press 1- 278...............................................................................................................18727. P098, Stamping Press 1-279................................................................................................................193

28. P099, Stamping Press 1-280................................................................................................................19929. P100, Stamping Press 1-286................................................................................................................205

30. P101, Stamping Press 1-291................................................................................................................21131. P102, Stamping Press 1-292................................................................................................................217

32. P103, Stamping Press 1-293................................................................................................................22333. P104, Stamping Press 1-299................................................................................................................229

34. P105, Rollformer 7-141.........................................................................................................................23535. P106, Rollformer 7-240.........................................................................................................................241

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

36. P107, Stamping Press 1-261................................................................................................................247

37. P108, Stamping Press 1-266................................................................................................................25338. P109, Stamping Press 1-267................................................................................................................259

39. P110, Stamping Press 1-290................................................................................................................26540. P111, Stamping Press 1-301................................................................................................................271

41. P112, Stamping Press 1-302................................................................................................................27742. P113, Stamping Press 1-227................................................................................................................283

43. P114, Stamping Press 1-237................................................................................................................28944. P115, Screen Washer A........................................................................................................................295

45. P116, Screen Washer B........................................................................................................................30246. P117, Stamping Press 1-001................................................................................................................309

47. P118, Stamping Press 1-002................................................................................................................31548. P119, Stamping Press 1-003................................................................................................................321

49. P120, Stamping Press 1-014................................................................................................................32750. P121, Stamping Press 1-025................................................................................................................333

51. P122, Stamping Press 1-026................................................................................................................33952. P123, Stamping Press 1-034................................................................................................................345

53. P124, Stamping Press 1-048................................................................................................................35154. P125, Stamping Press 1-052................................................................................................................357

55. P126, Stamping Press 1-81..................................................................................................................36356. P127, Stamping Press 1-89..................................................................................................................369

57. P128, Stamping Press 1-90..................................................................................................................37558. P129, Stamping Press 1-92..................................................................................................................381

59. P130, Stamping Press 1-93..................................................................................................................38760. P131, Stamping Press 1-126................................................................................................................393

61. P132, Stamping Press 1-127................................................................................................................39962. P133, Stamping Press 1-128................................................................................................................405

63. P134, Stamping Press 1-129................................................................................................................41164. P135, Stamping Press 1-131................................................................................................................417

65. P136, Stamping Press 1-132................................................................................................................42366. P137, Stamping Press 1-133................................................................................................................429

67. P138, Stamping Press 1-138................................................................................................................43568. P139, Stamping Press 1-214................................................................................................................441

69. P140, Stamping Press 1-250................................................................................................................447

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

AuthorizationFacility ID: 0575010106Facility Description: American Trim, LLC, Sidney facility manufactures decorative and transportation products

for appliance and automotive industries.Application Number(s): A0020083, A0020084, A0020085, A0020086Permit Number: P0088868Permit Description: Initial Title V for coating and processesPermit Type: InitialIssue Date: 1/8/2009Effective Date: To be entered upon final issuanceExpiration Date: To be entered upon final issuanceSuperseded Permit Number:

This document constitutes issuance of an OAC Chapter 3745-77 Title V permit to:

American Trim L.L.C.1501 West Michigan StreetSidney, OH 45365-2490

Ohio EPA District Office or local air agency responsible for processing and administering your permit:

Ohio EPA DAPC, Southwest District Office401 East Fifth StreetDayton, OH 45402(937)285-6357

The above named entity is hereby granted a Title V permit pursuant to Chapter 3745-77 of the Ohio Administrative Code. This permit and the authorization to operate the air contaminant sources (emissions units) at this facility shall expire at midnight on the expiration date shown above. You will be sent a notice approximately 18 months prior to the expiration date regarding the renewal of this permit. If you do not receive a notice, please contact the Ohio EPA DAPC, Southwest District Office. If a renewal permit is not issued prior to the expiration date, the permittee may continue to operate pursuant to OAC rule 3745-77-08(E) and in accordance with the terms of this permit beyond the expiration date, if a timely renewal application is submitted. A renewal application will be considered timely if it is submitted no earlier than 18 months (540 days) and no later than 6 months (180 days) prior to the expiration date.

This permit is granted subject to the conditions attached hereto.

Ohio Environmental Protection Agency

Chris KorleskiDirector

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

A. Standard Terms and Conditions

Page 2 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

1. Federally Enforceable Standard Terms and Conditions

a) All Standard Terms and Conditions are federally enforceable, with the exception of those listed below which are enforceable under State law only:

(1) Standard Term and Condition A. 24., Reporting Requirements Related to Monitoring and Record Keeping Requirements of State-Only Enforceable Permit Terms and Conditions

(2) Standard Term and Condition A. 25., Records Retention Requirements for State-Only Enforceable Permit Terms and Conditions

(3) Standard Term and Condition A. 27., Scheduled Maintenance/Malfunction Reporting

(4) Standard Term and Condition A. 29., Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

(Authority for term: ORC 3704.036(A))

2. Monitoring and Related Record Keeping and Reporting Requirements

a) Except as may otherwise be provided in the terms and conditions for a specific emissions unit (i.e., in section C. Emissions Unit Terms and Conditions of this Title V permit), the permittee shall maintain records that include the following, where applicable, for any required monitoring under this permit:

(1) The date, place (as defined in the permit), and time of sampling or measurements.

(2) The date(s) analyses were performed.

(3) The company or entity that performed the analyses.

(4) The analytical techniques or methods used.

(5) The results of such analyses.

(6) The operating conditions existing at the time of sampling or measurement. (Authority for term: OAC rule 3745-77-07(A)(3)(b)(i))

b) Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created. Support information shall include all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in computerized form.

(Authority for term: OAC rule 3745-77-07(A)(3)(b)(ii))

c) The permittee shall submit required reports in the following manner:

(1) All reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviations caused by malfunctions shall be submitted in the following manner:

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Any malfunction, as defined in OAC rule 3745-15-06(B)(1), shall be promptly reported to the Ohio EPA in accordance with OAC rule 3745-15-06. In addition, to fulfill the OAC rule 3745-77-07(A)(3)(c) deviation reporting requirements for malfunctions, written reports that identify each malfunction that occurred during each calendar quarter (including each malfunction reported only verbally in accordance with OAC rule 3745-15-06) shall be submitted (i.e., postmarked) by January 31, April 30, July 31, and October 31 of each year in accordance with Standard Term and Condition A.2.c)(2) below; and each report shall cover the previous calendar quarter. An exceedance of the visible emission limitations specified in OAC rule 3745-17-07(A)(1) that is caused by a malfunction is not a violation and does not need to be reported as a deviation if the owner or operator of the affected air contaminant source or air pollution control equipment complies with the requirements of OAC rule 3745-17-07(A)(3)(c).

In accordance with OAC rule 3745-15-06, a malfunction reportable under OAC rule 3745-15-06(B) constitutes a violation of an emission limitation (or control requirement) and, therefore, is a deviation of the federally enforceable permit requirements. Even though verbal notifications and written reports are required for malfunctions pursuant to OAC rule 3745-15-06, the written reports required pursuant to this term must be submitted quarterly to satisfy the prompt reporting provision of OAC rule 3745-77-07(A)(3)(c).

In identifying each deviation caused by a malfunction, the permittee shall specify the emission limitation(s) (or control requirement(s)) for which the deviation occurred, describe each deviation, and provide the magnitude and duration of each deviation. For a specific malfunction, if this information has been provided in a written report that was submitted in accordance with OAC rule 3745-15-06, the permittee may simply reference that written report to identify the deviation. Nevertheless, all malfunctions, including those reported only verbally in accordance with OAC rule 3745-15-06, must be reported in writing on a quarterly basis.

Any scheduled maintenance, as referenced in OAC rule 3745-15-06(A)(1), that results in a deviation from a federally enforceable emission limitation (or control requirement) shall be reported in the same manner as described above for malfunctions.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

(2) Except as may otherwise be provided in the terms and conditions for a specific emissions unit (i.e., in section C. Emissions Unit Terms and Conditions of this Title V permit or, in some cases, in section B. Facility-Wide Terms and Conditions of this Title V permit), all reporting required in accordance with OAC rule 3745-77-07(A)(3)(c) for deviations of the emission limitations, operational restrictions, and control device operating parameter limitations shall be submitted in the following manner:

Written reports of (a) any deviations from federally enforceable emission limitations, operational restrictions, and control device operating parameter limitations, (b) the probable cause of such deviations, and (c) any corrective actions or preventive measures taken, shall be promptly made to the appropriate Ohio EPA District Office or local air agency. Except as provided below, the written reports shall be submitted (i.e., postmarked) by January 31, April 30, July 31, and October 31 of each year; and each report shall cover the previous calendar quarter.

In identifying each deviation, the permittee shall specify the emission limitation(s), operational restriction(s), and/or control device operating parameter limitation(s) for which the deviation occurred, describe each deviation, and provide the estimated magnitude and duration of each deviation.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

These written deviation reports shall satisfy the requirements of OAC rule 3745-77-07(A)(3)(c) pertaining to the submission of monitoring reports every six months and to the prompt reporting of all deviations. Full compliance with OAC rule 3745-77-07(A)(3)(c) requires reporting of all other deviations of the federally enforceable requirements specified in the permit as required by such rule.

If an emissions unit has a deviation reporting requirement for a specific emission limitation, operational restriction, or control device operating parameter limitation that is not on a quarterly basis (e.g., within 30 days following the end of the calendar month, or within 30 or 45 days after the exceedance occurs), that deviation reporting requirement satisfies the reporting requirements specified in this Standard Term and Condition for that specific emission limitation, operational restriction, or control device parameter limitation. Following the provisions of that non-quarterly deviation reporting requirement will also satisfy (for the deviations so reported) the requirements of OAC rule 3745-77-07(A)(3)(c) pertaining to the submission of monitoring reports every six months and to the prompt reporting of all deviations, and additional quarterly deviation reports for that specific emission limitation, operational restriction, or control device parameter limitation are not required pursuant to this Standard Term and Condition.

See A.29 below if no deviations occurred during the quarter.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

(3) All reporting required in accordance with the OAC rule 3745-77-07(A)(3)(c) for other deviations of the federally enforceable permit requirements which are not reported in accordance with Standard Term and Condition A.2)c)(2) above shall be submitted in the following manner:

Unless otherwise specified by rule, written reports that identify deviations of the following federally enforceable requirements contained in this permit; Standard Terms and Conditions: A.3, A.4, A.5, A.7.e), A.8, A.13, A.15, A.19, A.20, A.21, and A.23 of this Title V permit, as well as any deviations from the requirements in section C. Emissions Unit Terms and Conditions of this Title V permit, and any monitoring, record keeping, and reporting requirements, which are not reported in accordance with Standard Term and Condition A.2.c)(2) above shall be submitted (i.e., postmarked) to the appropriate Ohio EPA District Office or local air agency by January 31 and July 31 of each year; and each report shall cover the previous six calendar months. Unless otherwise specified by rule, all other deviations from federally enforceable requirements identified in this permit shall be submitted annually as part of the annual compliance certification, including deviations of federally enforceable requirements not specifically addressed by permit or rule for the insignificant activities or emissions levels (IEU) identified in section B. Facility-Wide Terms and Conditions of this Title V permit. Annual reporting of deviations is deemed adequate to meet the deviation reporting requirements for IEUs unless otherwise specified by permit or rule.

In identifying each deviation, the permittee shall specify the federally enforceable requirement for which the deviation occurred, describe each deviation, and provide the magnitude and duration of each deviation.

These semi-annual and annual written reports shall satisfy the reporting requirements of OAC rule 3745-77-07(A)(3)(c) for any deviations from the federally enforceable requirements contained in this permit that are not reported in accordance with Standard Term and Condition A.2.c)(2) above.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

If no such deviations occurred during a six-month period, the permittee shall submit a semi-annual report which states that no such deviations occurred during that period.(Authority for term: OAC rules 3745-77-07(A)(3)(c)(i) and (ii) and OAC rule 3745-77-07(A)(13)(b))

(4) Each written report shall be signed by a responsible official certifying that, "based on information and belief formed after reasonable inquiry, the statements and information in the report (including any written malfunction reports required by OAC rule 3745-15-06 that are referenced in the deviation reports) are true, accurate, and complete."

(Authority for term: OAC rule 3745-77-07(A)(3)(c)(iv))

(5) Reports of any required monitoring and/or record keeping information shall be submitted to Ohio EPA DAPC, Southwest District Office.

(Authority for term: OAC rule 3745-77-07(A)(3)(c))

3. Scheduled Maintenance

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. Except as provided in OAC rule 3745-15-06(A)(3), any scheduled maintenance necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the emissions unit(s) that is (are) served by such control system(s). Any scheduled maintenance, as defined in OAC rule 3745-15-06(A)(1), that results in a deviation from a federally enforceable emission limitation (or control requirement) shall be reported in the same manner as described for malfunctions in Standard Term and Condition A.2.c)(1) above.(Authority for term: OAC rule 3745-77-07(A)(3)(c))

4. Risk Management Plans

If applicable, the permittee shall develop and register a risk management plan pursuant to section 112(r) of the Clean Air Act, as amended, 42 U.S.C. § 7401 et seq. ("Act"); and, pursuant to 40 C.F.R. 68.215(a), the permittee shall submit either of the following:

a) a compliance plan for meeting the requirements of 40 C.F.R. Part 68 by the date specified in 40 C.F.R. 68.10(a) and OAC 3745-104-05(A); or

b) as part of the compliance certification submitted under 40 C.F.R. 70.6(c)(5), a certification statement that the source is in compliance with all requirements of 40 C.F.R. Part 68 and OAC Chapter 3745-104, including the registration and submission of the risk management plan.

(Authority for term: OAC rule 3745-77-07(A)(4))

5. Title IV Provisions

If the permittee is subject to the requirements of 40 CFR Part 72 concerning acid rain, the permittee shall ensure that any affected emissions unit complies with those requirements. Emissions exceeding any allowances that are lawfully held under Title IV of the Act, or any regulations adopted thereunder, are prohibited.(Authority for term: OAC rule 3745-77-07(A)(5))

Page 6 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

6. Severability Clause

A determination that any term or condition of this permit is invalid shall not invalidate the force or effect of any other term or condition thereof, except to the extent that any other term or condition depends in whole or in part for its operation or implementation upon the term or condition declared invalid.(Authority for term: OAC rule 3745-77-07(A)(6))

7. General Requirements

a) The permittee must comply with all terms and conditions of this permit. Any noncompliance with the federally enforceable terms and conditions of this permit constitutes a violation of the Act, and is grounds for enforcement action or for permit revocation, revocation and reissuance, or modification, or for denial of a permit renewal application.

b) It shall not be a defense for the permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the federally enforceable terms and conditions of this permit.

c) This permit may be modified, reopened, revoked, or revoked and reissued, for cause, in accordance with Standard Term and Condition A.11 below. The filing of a request by the permittee for a permit modification, revocation and reissuance, or revocation, or of a notification of planned changes or anticipated noncompliance does not stay any term and condition of this permit.

d) This permit does not convey any property rights of any sort, or any exclusive privilege.

e) The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying, reopening or revoking this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the Director or an authorized representative of the Director, copies of records required to be kept by this permit. For information claimed to be confidential in the submittal to the Director, if the Administrator of the U.S. EPA requests such information, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.

f) Except as otherwise indicated below, this Title V permit, or permit modification, is effective for five years from the original effective date specified in the permit. In the event that this facility becomes eligible for non-title V permits, this permit shall cease to be enforceable when:

(1) the permittee submits an approved facility-wide potential to emit analysis supporting a claim that the facility no longer meets the definition of a "major source" as defined in OAC rule 3745-77-01(W) based on the permanent shutdown and removal of one or more emissions units identified in this permit; or

(2) the permittee no longer meets the definition of a "major source" as defined in OAC rule 3745-77-01(W) based on obtaining restrictions on the facility-wide potential(s) to emit that are federally enforceable or legally and practically enforceable ; or

(3) a combination of (1) and (2) above.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

The permittee shall continue to comply with all applicable OAC Chapter 3745-31 requirements for all regulated air contaminent sources once this permit ceases to be enforceable. The permittee shall comply with any residual requirements, such as quarterly deviation reports, semi-annual deviation reports, and annual compliance certifications covering the period during which this Title V permit was enforceable. All records relating to this permit must be maintained in accordance with law.(Authority for term: OAC rule 3745-77-01(W), OAC rule 3745-77-07(A)(3)(b)(ii), OAC rule 3745-77(A)(7))

8. Fees

The permittee shall pay fees to the Director of the Ohio EPA in accordance with ORC section 3745.11 and OAC Chapter 3745-78.(Authority for term: OAC rule 3745-77-07(A)(8))

9. Marketable Permit Programs

No revision of this permit is required under any approved economic incentive, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for in this permit.(Authority for term: OAC rule 3745-77-07(A)(9))

10. Reasonably Anticipated Operating Scenarios

The permittee is hereby authorized to make changes among operating scenarios authorized in this permit without notice to the Ohio EPA, but, contemporaneous with making a change from one operating scenario to another, the permittee must record in a log at the permitted facility the scenario under which the permittee is operating. The permit shield provided in these standard terms and conditions shall apply to all operating scenarios authorized in this permit.(Authority for term: OAC rule 3745-77-07(A)(10))

11. Reopening for Cause

This Title V permit will be reopened prior to its expiration date under the following conditions:

a) Additional applicable requirements under the Act become applicable to one or more emissions units covered by this permit, and this permit has a remaining term of three or more years. Such a reopening shall be completed not later than eighteen (18) months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms and conditions has been extended pursuant to paragraph (E)(1) of OAC rule 3745-77-08.

b) This permit is issued to an affected source under the acid rain program and additional requirements (including excess emissions requirements) become applicable. Upon approval by the Administrator, excess emissions offset plans shall be deemed to be incorporated into the permit, and shall not require a reopening of this permit.

c) The Director of the Ohio EPA or the Administrator of the U.S. EPA determines that the federally applicable requirements in this permit are based on a material mistake, or that inaccurate

Page 8 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

statements were made in establishing the emissions standards or other terms and conditions of this permit related to such federally applicable requirements.

d) The Administrator of the U.S. EPA or the Director of the Ohio EPA determines that this permit must be revised or revoked to assure compliance with the applicable requirements.

(Authority for term: OAC rules 3745-77-07(A)(12) and 3745-77-08(D))

12. Federal and State Enforceability

Only those terms and conditions designated in this permit as federally enforceable, that are required under the Act, or any of its applicable requirements, including relevant provisions designed to limit the potential to emit of a source, are enforceable by the Administrator of the U.S. EPA, the State, and citizens under the Act. All other terms and conditions of this permit shall not be federally enforceable and shall be enforceable under State law only.(Authority for term: OAC rule 3745-77-07(B))

13. Compliance Requirements

a) Any document (including reports) required to be submitted and required by a federally applicable requirement in this Title V permit shall include a certification by a responsible official that, based on information and belief formed after reasonable inquiry, the statements in the document are true, accurate, and complete.

b) Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the Director of the Ohio EPA or an authorized representative of the Director to:

(1) At reasonable times, enter upon the permittee's premises where a source is located or the emissions-related activity is conducted, or where records must be kept under the conditions of this permit.

(2) Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit, subject to the protection from disclosure to the public of confidential information consistent with paragraph (E) of OAC rule 3745-77-03.

(3) Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit.

(4) As authorized by the Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit and applicable requirements.

c) The permittee shall submit progress reports to the appropriate Ohio EPA District Office or local air agency concerning any schedule of compliance for meeting an applicable requirement. Progress reports shall be submitted semiannually or more frequently if specified in the applicable requirement or by the Director of the Ohio EPA. Progress reports shall contain the following:

(1) Dates for achieving the activities, milestones, or compliance required in any schedule of compliance, and dates when such activities, milestones, or compliance were achieved.

(2) An explanation of why any dates in any schedule of compliance were not or will not be met, and any preventive or corrective measures adopted.

Page 9 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

d) Compliance certifications concerning the terms and conditions contained in this permit that are federally enforceable emission limitations, standards, or work practices, shall be submitted to the Director (the appropriate Ohio EPA District Office or local air agency) and the Administrator of the U.S. EPA in the following manner and with the following content:

(1) Compliance certifications shall be submitted annually on a calendar year basis. The annual certification shall be submitted (i.e., postmarked) on or before April 30th of each year during the permit term.

(2) Compliance certifications shall include the following:

(a) An identification of each term or condition of this permit that is the basis of the certification.

(b) The permittee's current compliance status.

(c) Whether compliance was continuous or intermittent.

(d) The method(s) used for determining the compliance status of the source currently and over the required reporting period.

(e) Such other facts as the Director of the Ohio EPA may require in the permit to determine the compliance status of the source.

(3) Compliance certifications shall contain such additional requirements as may be specified pursuant to sections 114(a)(3) and 504(b) of the Act.

(Authority for term: OAC rules 3745-77-07(C)(1),(2),(4) and (5) and ORC section 3704.03(L))

14. Permit Shield

a) Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC rule 3745-77-07) shall be deemed compliance with the applicable requirements identified and addressed in this permit as of the date of permit issuance.

b) This permit shield provision shall apply to any requirement identified in this permit pursuant to OAC rule 3745-77-07(F)(2), as a requirement that does not apply to the source or to one or more emissions units within the source.

(Authority for term: OAC rule 3745-77-07(F))

15. Operational Flexibility

The permittee is authorized to make the changes identified in OAC rule 3745-77-07(H)(1)(a) to (H)(1)(c) within the permitted stationary source without obtaining a permit revision, if such change is not a modification under any provision of Title I of the Act [as defined in OAC rule 3745-77-01(JJ)], and does not result in an exceedance of the emissions allowed under this permit (whether expressed therein as a rate of emissions or in terms of total emissions), and the permittee provides the Administrator of the U.S. EPA and the appropriate Ohio EPA District Office or local air agency with written notification within a minimum of seven days in advance of the proposed changes, unless the change is associated with,

Page 10 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

or in response to, emergency conditions. If less than seven days notice is provided because of a need to respond more quickly to such emergency conditions, the permittee shall provide notice to the Administrator of the U.S. EPA and the appropriate District Office of the Ohio EPA or local air agency as soon as possible after learning of the need to make the change. The notification shall contain the items required under OAC rule 3745-77-07(H)(2)(d).(Authority for term: OAC rules 3745-77-07(H)(1) and (2))

16. Emergencies

The permittee shall have an affirmative defense of emergency to an action brought for noncompliance with technology-based emission limitations if the conditions of OAC rule 3745-77-07(G)(3) are met. This emergency defense provision is in addition to any emergency or upset provision contained in any applicable requirement.(Authority for term: OAC rule 3745-77-07(G))

17. Off-Permit Changes

The owner or operator of a Title V source may make any change in its operations or emissions at the source that is not specifically addressed or prohibited in the Title V permit, without obtaining an amendment or modification of the permit, provided that the following conditions are met:

a) The change does not result in conditions that violate any applicable requirements or that violate any existing federally enforceable permit term or condition.

b) The permittee provides contemporaneous written notice of the change to the Director and the Administrator of the U.S. EPA, except that no such notice shall be required for changes that qualify as insignificant emissions levels or activities as defined in OAC rule 3745-77-01(U). Such written notice shall describe each such change, the date of such change, any change in emissions or pollutants emitted, and any federally applicable requirement that would apply as a result of the change.

c) The change shall not qualify for the permit shield under OAC rule 3745-77-07(F).

d) The permittee shall keep a record describing all changes made at the source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from those changes.

e) The change is not subject to any applicable requirement under Title IV of the Act or is not a modification under any provision of Title I of the Act.

Paragraph (I) of rule 3745-77-07 of the Administrative Code applies only to modification or amendment of the permittee's Title V permit. The change made may require a permit-to-install under Chapter 3745-31 of the Administrative Code if the change constitutes a modification as defined in that Chapter. Nothing in paragraph (I) of rule 3745-77-07 of the Administrative Code shall affect any applicable obligation under Chapter 3745-31 of the Administrative Code.(Authority for term: OAC rule 3745-77-07(I))

Page 11 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

18. Compliance Method Requirements

Nothing in this permit shall alter or affect the ability of any person to establish compliance with, or a violation of, any applicable requirement through the use of credible evidence to the extent authorized by law. Nothing in this permit shall be construed to waive any defenses otherwise available to the permittee, including but not limited to, any challenge to the Credible Evidence Rule (see 62 Fed. Reg. 8314, Feb. 24, 1997), in the context of any future proceeding.(This term is provided for informational purposes only.)

19. Insignificant Activities or Emissions Levels

Each IEU that has one or more applicable requirements shall comply with those applicable requirements.(Authority for term: OAC rule 3745-77-07(A)(1))

20. Permit to Install Requirement

Prior to the "installation" or "modification" of any "air contaminant source," as those terms are defined in OAC rule 3745-31-01, a permit to install must be obtained from the Ohio EPA pursuant to OAC Chapter 3745-31.(Authority for term: OAC rule 3745-77-07(A)(1))

21. Air Pollution Nuisance

The air contaminants emitted by the emissions units covered by this permit shall not cause a public nuisance, in violation of OAC rule 3745-15-07.(Authority for term: OAC rule 3745-77-07(A)(1))

22. Permanent Shutdown of an Emissions Unit

The permittee may notify Ohio EPA of any emissions unit that is permanently shut down by submitting a certification from the responsible official that identifies the date on which the emissions unit was permanently shut down. Authorization to operate the affected emissions unit shall cease upon the date certified by the responsible official that the emissions unit was permanently shut down.

After the date on which an emissions unit is permanently shut down (i.e., that has been physically removed from service or has been altered in such a way that it can no longer operate without a subsequent "modification" or "installation" as defined in OAC Chapter 3745-31 and therefore ceases to meet the definition of an "emissions unit" as defined in OAC rule 3745-77-01(O)), rendering existing permit terms and conditions irrelevant, the permittee shall not be required, after the date of the certification and submission to Ohio EPA, to meet any Title V permit requirements applicable to that emissions unit, except for any residual requirements, such as the quarterly deviation reports, semi-annual deviation reports and annual compliance certification covering the period during which the emissions unit last operated. All records relating to the shutdown emissions unit, generated while the emissions unit was in operation, must be maintained in accordance with law.

No emissions unit certified by the responsible official as being permanently shut down may resume operation without first applying for and obtaining a permit to install pursuant to OAC Chapter 3745-31.

(Authority for term: OAC rule 3745-77-01)

Page 12 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

23. Title VI Provisions

If applicable, the permittee shall comply with the standards for recycling and reducing emissions of ozone depleting substances pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners in Subpart B of 40 CFR Part 82:

a) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices specified in 40 CFR 82.156.

b) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment specified in 40 CFR 82.158.

c) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to 40 CFR 82.161.

(Authority for term: OAC rule 3745-77-01(H)(11))

24. Reporting Requirements Related to Monitoring and Record Keeping Requirements Under State Law Only

The permittee shall submit required reports in the following manner:

a) Reports of any required monitoring and/or record keeping information shall be submitted to the appropriate Ohio EPA District Office or local air agency.

b) Except as otherwise may be provided in the terms and conditions for a specific emissions unit, quarterly written reports of (i) any deviations (excursions) from emission limitations, operational restrictions, and control device operating parameter limitations that have been detected by the testing, monitoring, and record keeping requirements specified in this permit, (ii) the probable cause of such deviations, and (iii) any corrective actions or preventive measures which have been or will be taken, shall be submitted to the appropriate Ohio EPA District Office or local air agency. In identifying each deviation, the permittee shall specify the applicable requirement for which the deviation occurred, describe each deviation, and provide the magnitude and duration of each deviation. If no deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. The reports shall be submitted (i.e., postmarked) quarterly, by January 31, April 30, July 31, and October 31 of each year and shall cover the previous calendar quarters. (These quarterly reports shall exclude deviations resulting from malfunctions reported in accordance with OAC rule 3745-15-06.)

25. Records Retention Requirements Under State Law Only

Each record of any monitoring data, testing data, and support information required pursuant to this permit shall be retained for a period of five years from the date the record was created. Support information shall include, but not be limited to, all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Such records may be maintained in computerized form.

Page 13 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

26. Inspections and Information Requests

The Director of the Ohio EPA, or an authorized representative of the Director, may, subject to the safety requirements of the permittee and without undue delay, enter upon the premises of this source at any reasonable time for purposes of making inspections, conducting tests, examining records or reports pertaining to any emission of air contaminants, and determining compliance with any applicable State air pollution laws and regulations and the terms and conditions of this permit. The permittee shall furnish to the Director of the Ohio EPA, or an authorized representative of the Director, upon receipt of a written request and within a reasonable time, any information that may be requested to determine whether cause exists for modifying, reopening or revoking this permit or to determine compliance with this permit. Upon verbal or written request, the permittee shall also furnish to the Director of the Ohio EPA, or an authorized representative of the Director, copies of records required to be kept by this permit.(Authority for term: OAC rule 3745-77-07(C))

27. Scheduled Maintenance/Malfunction Reporting

Any scheduled maintenance of air pollution control equipment shall be performed in accordance with paragraph (A) of OAC rule 3745-15-06. The malfunction of any emissions units or any associated air pollution control system(s) shall be reported to the appropriate Ohio EPA District Office or local air agency in accordance with paragraph (B) of OAC rule 3745-15-06. Except as provided in that rule, any scheduled maintenance or malfunction necessitating the shutdown or bypassing of any air pollution control system(s) shall be accompanied by the shutdown of the emissions unit(s) that is (are) served by such control system(s).

28. Permit Transfers

Any transferee of this permit shall assume the responsibilities of the prior permit holder. The appropriate Ohio EPA District Office or local air agency must be notified in writing of any transfer of this permit.(Authority for term: OAC rule 3745-77-01(C))

29. Additional Reporting Requirements When There Are No Deviations of Federally Enforceable Emission Limitations, Operational Restrictions, or Control Device Operating Parameter Limitations

If no emission limitation (or control requirement), operational restriction and/or control device parameter limitation deviations occurred during a calendar quarter, the permittee shall submit a quarterly report, which states that no deviations occurred during that quarter. The reports shall be submitted (i.e., postmarked) by January 31, April 30, July 31, and October 31 of each year; and each report shall cover the previous calendar quarter.

The permittee is not required to submit a quarterly report which states that no deviations occurred during that quarter for the following situations:

a) where an emissions unit has deviation reporting requirements for a specific emission limitation, operational restriction, or control device parameter limitation that override the deviation reporting requirements specified in Standard Term and Condition A.2.c)(2); or

Page 14 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b) where an uncontrolled emissions unit has no monitoring, record keeping, or reporting requirements and the emissions unit's applicable emission limitations are established at the potentials to emit; or

c) where the company's responsible official has certified that an emissions unit has been permanently shut down.

B. Facility-Wide Terms and Conditions1.

Page 15 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

1. All the following facility-wide terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only:

a) None.

2.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

C. Emissions Unit Terms and Conditions

Page 17 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

1. B001, Bumper 200 AMU

Operations, Property and/or Equipment Description:

Bumper 200 Air Makeup Unit (12.375 mmBtu); air makeup

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) None.

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3)PTI 05-13323

Visible PE shall not exceed 10% opacity as a 6-minute average.

The particulate emissions shall not exceed 0.020 pound per million Btu of actual heat input.

Emission Limitations:

0.09 lb/hr and 0.4 TPY PE0.21 lb/hr and 0.91 TPY SO22.57 lb/hr and 11.26 TPY NOx1.02 lb/hr and 4.46 TPY CO0.13 lb/hr and 0.58 TPY VOC

b)(2)a. and b)(2)b, below.b. OAC rule 3745-17-07(A) The emissions limitation specified by this

rule is less stringent than the emission limitation established pursuant to OAC rule 3745-31-05(A)(3).

c. OAC rule 3745-17-10(B)(1) The emissions limitation specified by this rule is less stringent than the emission limitation established pursuant to OAC rule 3745-31-05(A)(3).

(2) Additional Terms and Conditions

a. The "Best Available Technology" (BAT) control requirement for this emissions unit has been determined to be compliance with the terms and conditions of this permit.

Page 18 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. The hourly emission limitations were established for purposes to reflect the emission unit's potential to emit. Therefore, no additional monitoring, record keeping or reporting is required to demonstrate compliance with these emission limitations.

c) Operational Restrictions

(1) The permittee shall burn only natural gas or propane in this emissions unit.

d) Monitoring and/or Recordkeeping Requirements

(1) For each day during which the permittee burns a fuel other than natural gas or propane the permittee shall maintain a record of the type and quantity of fuel burned in this emissions unit.

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. when a fuel other than natural gas or propane was burned in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in the terms and conditions of this permit shall be determined in accordance with the following methods:

Emission Limitations:

0.09 lb/hr and 0.4 TPY PE

0.21 lb/hr and 0.91 TPY SO2

2.57 lb/hr and 11.26 TPY NOx

1.02 lb/hr and 4.46 TPY CO

0.13 lb/hr and 0.58 TPY VOC

Applicable Compliance Method:

The hourly allowable emission limitations above were established by multiplying the maximum natural gas or propane usage rate (12.375 mmBtu/hr) by the higher of the emission factors* for each pollutant, from AP-42, Tables 1.4-1, and 1.4-2, revised 7/98 (for natural gas) and Table 1.5-1, revised October 1996 (for propane).

Page 19 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* for NOx: 0.21 lb NOx/mmBtu; for CO, 0.08 lb CO/mmBtu; for PE, 0.007 lb PE/mmBtu; for VOC, 0.01 lb VOC/mmBtu; and for SO2, 0.017 lb SO2/mmBtu.

If required, compliance with the hourly allowable emission limitations above shall be determined in accordance with the appropriate Methods** of 40 CFR Part 60, Appendix A.

** For NOx, Methods 1 - 4 and 7; for CO, Methods 1 - 4 and 10; for VOC, Methods 1 - 4 and 25 or 25A, as appropriate; for PE, Methods 1 - 5; and for SO2, Methods 1 - 4 and 6.

g) Miscellaneous Requirements

(1) None.

Page 20 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

2. K005, Coating/Printing Press C-5

Operations, Property and/or Equipment Description:

Metal Decorative Coating Press

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(5).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. 3745-31-05(A)(3)PTI 05-14397

The Volatile organic compound (VOC) content of the coatings shall not exceed 5.35 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.6 lb/hr and 2.714 tons/yr nitrogen oxides (NOx)0.252 lb/hr and 1.104 ton/yr carbon monoxide (CO)0.02 lb/hr and 0.086 ton/yr filterable particulate emissions (PE)0.023 lb/hr and 0.1 ton/yr PM100.002 lb/hr and 0.008 ton/yr sulfur dioxide (SO2)0.017 lb/hr and 0.072 ton/yr VOC

See Sections b)(2)a., c)(1), c)(2), d)(1), d)(3), e)(1), f)(1)a., and f)(1)f., below

b. OAC rule 3745-31-05(D)

(synthetic minor to avoid the requirements of 40 CFR Part 63, Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)b., d)(4), e)(1), and f)(1)c., below.

Page 21 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

c. OAC rule 3745-31-05(F) The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

See Sections c)(2), d)(2), e)(1), and f)(1)b., below.

d. OAC rule 3745-21-09(U)(2)(e)(iii) The coatings usage in this emissions unit shall not exceed 10 gallons per day.

See Sections d)(1), e)(2), and f)(1)d., below.

e. OAC rule 3745-17-10(B) 0.02 lb PE per mmBtu for the drying oven

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)e., below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(5), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

Page 22 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) The combined emissions of VOC from emissions units K005 through K009, inclusive, shall not exceed 14.87 tons per rolling, 12-month period, calculated according to the following formula:

14.87 ≥ ∑n=1

i

( (Pi ) x(VOCi)2000 )−¿( (Rp ) x (Po ) x (VOCo )

2000 )¿Where:

Pi = usage of each coating, cleanup, or restoration material in gallons;

VOCi = volatile Organic compound content of each coating, cleanup, or restoration material in pounds VOC per gallon;

Rp =ratio of solvent used on emissions units K005 through K009 (total solvent used on all emissions units - the amount of solvent used on emissions unit K045);

Po =total gallons of recovered solvents less the gallons of solvent recovered from emissions unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each day this emissions unit is in operation:

a. the name and identification number of each coating employed;

b. the volume, in gallons, of each coating employed;

c. the total volume, in gallons, of all the coatings employed; and

d. the VOC content of each coating employed, in lbs/gallon of coating.

(2) The permittee shall collect and record the following information each month for emissions units K005 through K009, inclusive, combined:

a. the name or identification number for each coating and cleanup/restoration solvent employed;

b. the VOC content of each coating and cleanup/restoration solvent material employed, in pounds per gallon, as applied;

c. the volume, in gallons, of each coating and cleanup/restoration solvent material employed;

d. the VOC emissions, in tons, as determined by the equation in Section c)(2), of these terms and conditions; and

e. the rolling, 12-month VOC emissions, in tons.

Page 23 of 452

Page 32: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(5) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

Page 24 of 452

Page 33: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable coatings VOC content of 5.35 pounds per gallon, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 14.87 tons (for emissions units K005 through K009, combined);

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average.

e. The permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)].

(2) The permittee shall notify the Director any daily record showing that the coating line employs more than the applicable maximum daily coating usage limit. A copy of such record shall be sent to the director within forty-five days after the exceedance occurs.

[OAC rule 3745-21-09(B)(3)(e)]

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

The VOC content of the coatings shall not exceed 5.35 pounds per gallon of coating.

Applicable Compliance Method:

Compliance with the allowable VOC content limitation above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

Page 25 of 452

Page 34: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. Emission Limitation:

The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(4) of this permit.

d. Operational Restriction:

10 gallons of coatings/day

Applicable Compliance Method:

Compliance with the operational restriction above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

e. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

f. Emission Limitations:

i. 0.6 lb/hr and 2.714 tons/yr NOx

ii. 0.252 lb/hr and1.104 ton/yr CO

iii. 0.02 lb/hr and 0.086 ton/yr PE

iv. 0.023 lb/hr and 0.1 ton/yr PM10

Page 26 of 452

Page 35: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

v. 0.002 lb/hr and 0.008 ton/yr SO2

vi. 0.017 lb/hr and 0.072 ton/yr VOC

vii. 3.41 lb/hr and 14.92 ton/yr VOC *

* Combined allowable from emissions units K005-K009.

Applicable Compliance Method:

The permittee may demonstrate compliance with the hourly allowable emission limitations above by multiplying the maximum hourly natural gas/propane consumption rate by the appropriate emission factor from USEPA's AP-42.

If required, the permittee shall demonstrate compliance with the hourly allowable emission limitations above based on the results of emission testing conducted in accordance with the following Methods:

i. for NOx, Methods 1 - 4 and 7 of 40 CFR Part 60, Appendix A;

ii. for CO, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A;

iii. for PE, Methods 1 - 5 of 40 CFR Part 60, Appendix A;

iv. for PM10, Methods 201 and 202 of 40 CFR Part 60, Appendix A;

v. for SO2, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A; and

vi. for VOC, Methods 18, 25, or 25A, as appropriate, of 40 CFR Part 60, Appendix A.

Compliance with the annual allowable emission limitations above shall be ensured as long as compliance with the hourly allowable emission limitations is maintained (the annual allowable limitations were determined by multiplying the hourly allowable limitations by 8760, and them dividing by 2000).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

Page 27 of 452

Page 36: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

g) Miscellaneous Requirements

(1) None.

Page 28 of 452

Page 37: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

3. K006, Coating/Printing Press C-4

Operations, Property and/or Equipment Description:

Metal Decorative Coating Press

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(5).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. 3745-31-05(A)(3)(PTI 05-14394)

The Volatile organic compound (VOC) content of the coatings shall not exceed 5.35 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.413 lb/hr and 1.809 tons/yr nitrogen oxides (NOx)0.168 lb/hr and 0.736 ton/yr carbon monoxide (CO)0.01 lb/hr and 0.057 ton/yr filterable particulate emissions (PE)0.015 lb/hr and 0.067 ton/yr PM100.001 lb/hr and 0.005 ton/yr sulfur dioxide (SO2)0.011 lb/hr and 0.048 ton/yr VOC

See Sections b)(2)a., c)(1), c)(2), d)(1), d)(3), e)(1), f)(1)a., and f)(1)f., below.

b. OAC rule 3745-31-05(D)

(Synthetic Minor to avoid the requirements of 40 CFR Part 63, Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)b., d)(4), e)(1), and f)(1)c., below.

Page 29 of 452

Page 38: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

c. OAC rule 3745-31-05(F) The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

See Sections c)(2), d)(2), e)(1), and f)(1)b., below.

d. OAC rule 3745-21-09(U)(2)(e)(iii) The coatings usage in this emissions unit shall not exceed 10 gallons per day.

See Sections d)(1), e)(2), and f)(1)d., below.

e. OAC rule 3745-17-10(B) 0.02 lbs of PE per mmBtu for Drying oven(s)

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)e., below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(5), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

Page 30 of 452

Page 39: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) The combined emissions of VOC from emissions units K005 through K009, inclusive, shall not exceed 14.87 tons per rolling, 12-month period, calculated according to the following formula:

14.87 ≥ ∑n=1

i

( (Pi ) x(VOCi)2000 )−¿( (Rp ) x (Po ) x (VOCo )

2000 )¿Where:

Pi = usage of each coating, cleanup, or restoration material in gallons;

VOCi = volatile Organic compound content of each coating, cleanup, or restoration material in pounds VOC per gallon;

Rp =ratio of solvent used on emissions units K005 through K009 (total solvent used on all emissions units - the amount of solvent used on emissions unit K045);

Po =total gallons of recovered solvents less the gallons of solvent recovered from emissions unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each day this emissions unit is in operation:

a. the name and identification number of each coating employed;

b. the volume, in gallons, of each coating employed;

c. the total volume, in gallons, of all the coatings employed; and

d. the VOC content of each coating employed, in lbs/gallon of coating.

(2) The permittee shall collect and record the following information each month for emissions units K005 through K009, inclusive, combined:

a. the name or identification number for each coating and cleanup/restoration solvent employed;

b. the VOC content of each coating and cleanup/restoration solvent material employed, in pounds per gallon, as applied;

c. the volume, in gallons, of each coating and cleanup/restoration solvent material employed;

d. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

e. the rolling, 12-month VOC emissions, in tons.

Page 31 of 452

Page 40: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(5) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

Page 32 of 452

Page 41: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable coatings VOC content of 5.35 pounds per gallon, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 14.87 tons (for emissions units K005 through K009, combined);

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average.

e. The permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)].

(2) The permittee shall notify the Director any daily record showing that the coating line employs more than the applicable maximum daily coating usage limit. A copy of such record shall be sent to the director within forty-five days after the exceedance occurs.

[OAC rule 3745-21-09(B)(3)(e)]

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

The VOC content of the coatings shall not exceed 5.35 pounds per gallon of coating.

Applicable Compliance Method:

Compliance with the allowable VOC content limitation above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

Page 33 of 452

Page 42: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. Emission Limitation:

The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(4) of this permit.

d. Operational Restriction:

10 gallons of coatings/day

Applicable Compliance Method:

Compliance with the operational restriction above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

e. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

f. Emission Limitations:

i. 0.413 lb/hr and 1.809 tons/yr nitrogen oxides (NOx)

ii. 0.168 lb/hr and 0.736 ton/yr carbon monoxide (CO)

iii. 0.01 lb/hr and 0.057 ton/yr filterable particulate emissions (PE)

iv. 0.015 lb/hr and 0.067 ton/yr PM10

Page 34 of 452

Page 43: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

v. 0.001 lb/hr and 0.005 ton/yr sulfur dioxide (SO2)

vi. 0.011 lb/hr and 0.048 ton/yr VOC

Applicable Compliance Method:

The permittee may demonstrate compliance with the hourly allowable emission limitations above by multiplying the maximum hourly natural gas/propane consumption rate by the appropriate emission factor from USEPA's AP-42.

If required, the permittee shall demonstrate compliance with the hourly allowable emission limitations above based on the results of emission testing conducted in accordance with the following Methods:

vii. for NOx, Methods 1 - 4 and 7 of 40 CFR Part 60, Appendix A;

viii. for CO, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A;

ix. for PE, Methods 1 - 5 of 40 CFR Part 60, Appendix A;

x. for PM10, Methods 201 and 202 of 40 CFR Part 60, Appendix A;

xi. for SO2, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A; and

xii. for VOC, Methods 18, 25, or 25A, as appropriate, of 40 CFR Part 60, Appendix A.

Compliance with the annual allowable emission limitations above shall be ensured as long as compliance with the hourly allowable emission limitations is maintained (the annual allowable limitations were determined by multiplying the hourly allowable limitations by 8760, and them dividing by 2000).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

g) Miscellaneous Requirements

(1) None.

Page 35 of 452

Page 44: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

4. K007, Coating/Printing Press C-3

Operations, Property and/or Equipment Description:

Metal Decorative Coating Press

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(5).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3)(PTI 05-13345)

The Volatile organic compound (VOC) content of the coatings shall not exceed 5.35 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.6 lb/hr and 2.714 tons/yr nitrogen oxides (NOx);0.252 lb/hr and 1.104 ton/yr carbon monoxide (CO);0.02 lb/hr and 0.086 ton/yr filterable particulate emissions (PE);0.023 lb/hr and 0.1 ton/yr PM10;0.002 lb/hr and 0.008 ton/yr sulfur dioxide (SO2); and0.017 lb/hr and 0.072 ton/yr VOC.

See Sections b)(2)a., c)(1), c)(2), d)(1), d)(3), e)(1), f)(1)a., and f)(1)f., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)b., d)(4), e)(1), and f)(1)c., below.

Page 36 of 452

Page 45: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

c. OAC rule 3745-31-05(F) The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

See Sections c)(2), d)(2), e)(1), and f)(1)b., below.

d. OAC rule 3745-21-09(U)(2)(e)(iii) The coatings usage in this emissions unit shall not exceed 10 gallons per day.

See Sections d)(1), e)(2), and f)(1)d., below.

e. OAC rule 3745-17-10(B) 0.02 lb PE per mmBtu for the drying oven

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)e., below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(5), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

Page 37 of 452

Page 46: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) The combined emissions of VOC from emissions units K005 through K009, inclusive, shall not exceed 14.87 tons per rolling, 12-month period, calculated according to the following formula:

14.87 ≥ ∑n=1

i

( (Pi ) x(VOCi)2000 )−¿( (Rp ) x (Po ) x (VOCo )

2000 )¿Where:

Pi = usage of each coating, cleanup, or restoration material in gallons;

VOCi = volatile Organic compound content of each coating, cleanup, or restoration material in pounds VOC per gallon;

Rp =ratio of solvent used on emissions units K005 through K009 (total solvent used on all emissions units - the amount of solvent used on emissions unit K045);

Po =total gallons of recovered solvents less the gallons of solvent recovered from emissions unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each day this emissions unit is in operation:

a. the name and identification number of each coating employed;

b. the volume, in gallons, of each coating employed;

c. the total volume, in gallons, of all the coatings employed; and

d. the VOC content of each coating employed, in lbs/gallon of coating.

(2) The permittee shall collect and record the following information each month for emissions units K005 through K009, inclusive, combined:

a. the name or identification number for each coating and cleanup/restoration solvent employed;

b. the VOC content of each coating and cleanup/restoration solvent material employed, in pounds per gallon, as applied;

c. the volume, in gallons, of each coating and cleanup/restoration solvent material employed;

d. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

e. the rolling, 12-month VOC emissions, in tons.

Page 38 of 452

Page 47: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(5) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

Page 39 of 452

Page 48: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable coatings VOC content of 5.35 pounds per gallon, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 14.87 tons (for emissions units K005 through K009, combined);

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average.

e. The permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)].

(2) The permittee shall notify the Director any daily record showing that the coating line employs more than the applicable maximum daily coating usage limit. A copy of such record shall be sent to the director within forty-five days after the exceedance occurs.

[OAC rule 3745-21-09(B)(3)(e)]

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

The VOC content of the coatings shall not exceed 5.35 pounds per gallon of coating.

Applicable Compliance Method:

Compliance with the allowable VOC content limitation above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

Page 40 of 452

Page 49: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. Emission Limitation:

The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(4) of this permit.

d. Operational Restriction:

10 gallons of coatings/day

Applicable Compliance Method:

Compliance with the operational restriction above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

e. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

f. Emission Limitations:

i. 0.6 lb/hr and 2.714 tons/yr NOx

ii. 0.252 lb/hr and1.104 ton/yr CO

iii. 0.02 lb/hr and 0.086 ton/yr PE

iv. 0.023 lb/hr and 0.1 ton/yr PM10

Page 41 of 452

Page 50: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

v. 0.002 lb/hr and 0.008 ton/yr SO2

vi. 0.017 lb/hr and 0.072 ton/yr VOC

vii. 3.41 lb/hr and 14.92 ton/yr VOC *

* Combined allowable from emissions units K005-K009.

Applicable Compliance Method:

The permittee may demonstrate compliance with the hourly allowable emission limitations above by multiplying the maximum hourly natural gas/propane consumption rate by the appropriate emission factor from USEPA's AP-42.

If required, the permittee shall demonstrate compliance with the hourly allowable emission limitations above based on the results of emission testing conducted in accordance with the following Methods:

viii. for NOx, Methods 1 - 4 and 7 of 40 CFR Part 60, Appendix A;

ix. for CO, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A;

x. for PE, Methods 1 - 5 of 40 CFR Part 60, Appendix A;

xi. for PM10, Methods 201 and 202 of 40 CFR Part 60, Appendix A;

xii. for SO2, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A; and

xiii. for VOC, Methods 18, 25, or 25A, as appropriate, of 40 CFR Part 60, Appendix A.

Compliance with the annual allowable emission limitations above shall be ensured as long as compliance with the hourly allowable emission limitations is maintained (the annual allowable limitations were determined by multiplying the hourly allowable limitations by 8760, and them dividing by 2000).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

Page 42 of 452

Page 51: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

5. K008, Coating/Printing Press C-2

Operations, Property and/or Equipment Description:

Metal Decorative Coating Press

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(5).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. 3745-31-05(A)(3) (PTI 05-13345)

The Volatile organic compound (VOC) content of the coatings shall not exceed 5.35 pounds per gallon.

Emissions from combustion of natural gas and propane in the drying oven shall not exceed the following limits:

0.15 lb/hr and 0.67 TPY NOx;0.08 lb/hr and 0.36 TPY CO;0.01 lb/hr and 0.03 TPY Filterable PM;0.02 lb/hr and 0.07 TPY SO2; and0.01 lb/hr and 0.02 TPY VOC.

See Sections b)(2)a., c)(1), c)(2), d)(1), d)(3), e)(1), f)(1)a., and f)(1)f., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)b., d)(4), e)(1), and f)(1)c., below.

c. OAC rule 3745-31-05(F) The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Page 43 of 452

Page 52: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control MeasuresSee Sections c)(2), d)(2), e)(1), and f)(1)b., below.

d. OAC rule 3745-21-09(U)(2)(e)(iii) The coatings usage in this emissions unit shall not exceed 10 gallons per day.

See Sections d)(1), e)(2), and f)(1)d., below.

e. OAC rule 3745-17-10(B) 0.02 lb PE per mmBtu for the drying oven

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)e., below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(5), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The combined emissions of VOC from emissions units K005 through K009, inclusive, shall not exceed 14.87 tons per rolling, 12-month period, calculated according to the following formula:

Page 44 of 452

Page 53: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

14.87 ≥ ∑n=1

i

( (Pi ) x(VOCi)2000 )−¿( (Rp ) x (Po ) x (VOCo )

2000 )¿Where:

Pi = usage of each coating, cleanup, or restoration material in gallons;

VOCi = volatile Organic compound content of each coating, cleanup, or restoration material in pounds VOC per gallon;

Rp =ratio of solvent used on emissions units K005 through K009 (total solvent used on all emissions units - the amount of solvent used on emissions unit K045);

Po =total gallons of recovered solvents less the gallons of solvent recovered from emissions unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each day this emissions unit is in operation:

a. the name and identification number of each coating employed;

b. the volume, in gallons, of each coating employed;

c. the total volume, in gallons, of all the coatings employed; and

d. the VOC content of each coating employed, in lbs/gallon of coating.

(2) The permittee shall collect and record the following information each month for emissions units K005 through K009, inclusive, combined:

a. the name or identification number for each coating and cleanup/restoration solvent employed;

b. the VOC content of each coating and cleanup/restoration solvent material employed, in pounds per gallon, as applied;

c. the volume, in gallons, of each coating and cleanup/restoration solvent material employed;

d. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

e. the rolling, 12-month VOC emissions, in tons.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

Page 45 of 452

Page 54: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(4) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(5) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

Page 46 of 452

Page 55: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. all exceedances of the maximum allowable coatings VOC content of 5.35 pounds per gallon, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 14.87 tons (for emissions units K005 through K009, combined);

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average.

e. The permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)].

(2) The permittee shall notify the Director any daily record showing that the coating line employs more than the applicable maximum daily coating usage limit. A copy of such record shall be sent to the director within forty-five days after the exceedance occurs.

[OAC rule 3745-21-09(B)(3)(e)]

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

The VOC content of the coatings shall not exceed 5.35 pounds per gallon of coating.

Applicable Compliance Method:

Compliance with the allowable VOC content limitation above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

b. Emission Limitation:

The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Page 47 of 452

Page 56: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(4) of this permit

d. Operational Restriction:

10 gallons of coatings/day

Applicable Compliance Method:

Compliance with the operational restriction above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

e. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

f. Emission Limitations:

i. 00.15 lb/hr and 0.67 TPY NOx;

ii. 0.08 lb/hr and 0.36 TPY CO;

iii. 0.01 lb/hr and 0.03 TPY Filterable PM;

iv. 0.02 lb/hr and 0.07 TPY SO2; and

v. 0.01 lb/hr and 0.02 TPY VOC.

Page 48 of 452

Page 57: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

The permittee may demonstrate compliance with the hourly allowable emission limitations above by multiplying the maximum hourly natural gas/propane consumption rate by the appropriate emission factor from USEPA's AP-42.

If required, the permittee shall demonstrate compliance with the hourly allowable emission limitations above based on the results of emission testing conducted in accordance with the following Methods:

i. for NOx, Methods 1 - 4 and 7 of 40 CFR Part 60, Appendix A;

ii. for CO, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A;

iii. for PE, Methods 1 - 5 of 40 CFR Part 60, Appendix A;

iv. for PM10, Methods 201 and 202 of 40 CFR Part 60, Appendix A;

v. for SO2, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A; and

vi. for VOC, Methods 18, 25, or 25A, as appropriate, of 40 CFR Part 60, Appendix A.

Compliance with the annual allowable emission limitations above shall be ensured as long as compliance with the hourly allowable emission limitations is maintained (the annual allowable limitations were determined by multiplying the hourly allowable limitations by 8760, and them dividing by 2000).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

Page 49 of 452

Page 58: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

6. K009, Coating/Printing Press C-1

Operations, Property and/or Equipment Description:

Metal Decorative Coating Press

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(5).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. 3745-31-05(A)(3)(PTI 05-13345)

The Volatile organic compound (VOC) content of the coatings shall not exceed 3.5 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.27 lb/hr and 1.17 TPY NOx;0.14 lb/hr and 0.63 TPY CO;0.01 lb/hr and 0.06 TPY Filterable PM;0.03 lb/hr and 0.13 TPY SO2; and0.01 lb/hr and 0.04 TPY VOC.

See Sections b)(2)a., c)(1), c)(2), d)(1), d)(3), e)(1), f)(1)a., and f)(1)e., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)b, d)(4), e)(1) and f)(1)c., below.

c. OAC rule 3745-31-05(F) The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Page 50 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control MeasuresSee Sections c)(2), d)(2), e)(1), and f)(1)b., below.

d. OAC rule 3745-21-09(U)(1)(c) The Volatile organic compound (VOC) content of the coatings shall not exceed 3.5 pounds per gallon.

See Sections d)(1), e)(2), and f)(1)d., below.

e. OAC rule 3745-17-10(B) 0.02 lb PE per mmBtu for the drying oven

See Sections c)(1), d)(3), e)(1), and f)(1)f., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)d., below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(5), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The combined emissions of VOC from emissions units K005 through K009, inclusive, shall not exceed 14.87 tons per rolling, 12-month period, calculated according to the following formula:

Page 51 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

14.87 ≥ ∑n=1

i

( (Pi ) x(VOCi)2000 )−¿( (Rp ) x (Po ) x (VOCo )

2000 )¿Where:

Pi = usage of each coating, cleanup, or restoration material in gallons;

VOCi = volatile Organic compound content of each coating, cleanup, or restoration material in pounds VOC per gallon;

Rp =ratio of solvent used on emissions units K005 through K009 (total solvent used on all emissions units - the amount of solvent used on emissions unit K045);

Po =total gallons of recovered solvents less the gallons of solvent recovered from emissions unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each day this emissions unit is in operation:

a. the name and identification number of each coating employed;

b. the volume, in gallons, of each coating employed;

c. the total volume, in gallons, of all the coatings employed; and

d. the VOC content of each coating employed, in lbs/gallon of coating.

(2) The permittee shall collect and record the following information each month for emissions units K005 through K009, inclusive, combined:

a. the name or identification number for each coating and cleanup/restoration solvent employed;

b. the VOC content of each coating and cleanup/restoration solvent material employed, in pounds per gallon, as applied;

c. the volume, in gallons, of each coating and cleanup/restoration solvent material employed;

d. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

e. the rolling, 12-month VOC emissions, in tons.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

Page 52 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(4) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(5) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

Page 53 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. all exceedances of the rolling, 12-month VOC emission limitation of 14.87 tons (for emissions units K005 through K009, combined);

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average.

d. The permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)].

(2) The permittee shall notify the Director (appropriate District Office or local air agency) in writing of each daily record showing a daily volume-weighted average greater than 3.5 pounds VOC per gallon, as applied, excluding water and exempt solvents. The notification shall include a copy of such record and shall be sent to the Director (appropriate District Office or local air agency) within 30 days after the exceedance occurs.

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

The VOC content of the coatings shall not exceed 3.5 pounds per gallon of coating.

Applicable Compliance Method:

Compliance with the allowable VOC content limitation above shall be demonstrated through the record keeping requirements as established in d)(1) of this permit.

b. Emission Limitation:

The VOC emissions, for emissions units K005 through K009, combined, shall not exceed 14.87 tons per rolling, 12-month period.

Page 54 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(4) of this permit.

d. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

e. Emission Limitations:

i. 0.27 lb/hr and 1.17 TPY NOx;

ii. 0.14 lb/hr and 0.63 TPY CO;

iii. 0.01 lb/hr and 0.06 TPY Filterable PM;

iv. 0.03 lb/hr and 0.13 TPY SO2; and

v. 0.01 lb/hr and 0.04 TPY VOC.

Applicable Compliance Method:

The permittee may demonstrate compliance with the hourly allowable emission limitations above by multiplying the maximum hourly natural gas/propane consumption rate by the appropriate emission factor from USEPA's AP-42.

If required, the permittee shall demonstrate compliance with the hourly allowable emission limitations above based on the results of emission testing conducted in accordance with the following Methods:

i. for NOx, Methods 1 - 4 and 7 of 40 CFR Part 60, Appendix A;

Page 55 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

ii. for CO, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A;

iii. for PE, Methods 1 - 5 of 40 CFR Part 60, Appendix A;

iv. for PM10, Methods 201 and 202 of 40 CFR Part 60, Appendix A;

v. for SO2, Methods 1 - 4 and 10 of 40 CFR Part 60, Appendix A; and

vi. for VOC, Methods 18, 25, or 25A, as appropriate, of 40 CFR Part 60, Appendix A.

Compliance with the annual allowable emission limitations above shall be ensured as long as compliance with the hourly allowable emission limitations is maintained (the annual allowable limitations were determined by multiplying the hourly allowable limitations by 8760, and them dividing by 2000).

f. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

Page 56 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

7. K022, A-Line Screen Presses

Operations, Property and/or Equipment Description:

Metal Decorative Coating Screen Press Printing Coating Line 172

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(6).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3) and (PTI 05-06270)

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.71 lb/hr and 3.1 tons/yr NOx;0.38 lb/hr and 1.67 tons/yr CO;0.04 lb/hr and 0.15 ton/yr PE;0.08 lb/hr and 0.34 ton/yr SO2; and0.03 lb/hr and 0.11 ton/yr VOC.

See Sections b)(2)b, c)(1), d)(3), e)(1), and f)(1)d., below.

b. OAC rule 3745-31-05(D) (Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c, d)(5), e)(1), and f)(1)c., below.

c. OAC rule 3745-31-05(F) The Volatile Organic Compound (VOC) emissions from coatings, pan, and cleanup materials shall not exceed 18.895 tons of VOC per rolling 12-month period.

See Sections c)(2), d)(1), e)(1), and f)(1)b., below.

d. 3745-21-09 (U)(2)(f) VOC content of coatings shall not exceed

Page 57 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures5.36 lbs VOC/gallon, minus water and exempt solvents, as applied.

See Sections b)(2)a., b)(2)d., d)(1), d)(4), e)(2), e)(3), and f)(1)a., below.

e. OAC rule 3745-17-10(B) 0.02 lbs PE per mmBtu for drying oven.

See Sections b)(2)b., c)(1), d)(3), e)(1), and f)(1)e., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)f, below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(6), below.

(2) Additional Terms and Conditions

a. Pursuant to OAC rule 3745-21-09(U)(2)(f)(ii), the best available technology has been determined to be extreme performance coatings that have a VOC content greater than the limitations of OAC rules 3745-21-09(U)(1)(c).

b. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

d. Extreme performance coatings are exempt by BAT determination in this permit and exemption under OAC rule 3745-21-09(U)(2)(f) in this permit from the requirements for extreme performance coatings in OAC rule 3745-21-09(U)(1). If at any time a non-extreme coating is used in this emissions unit, that coating must comply with the requirements of OAC rule 3745-21-09(U)(1).

For the purpose of discontinuing the coating evaluation under section d)(4) of this permit, the VOC content of extreme performance coating used in this emissions

Page 58 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

unit shall not exceed 3.5 lbs of VOC per gallon, as applied, minus water and exempt solvents.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The weight of volatile organic materials applied/used for K022 shall not exceed 18.895 tons per rolling 12 months, calculated using the following formula:

18.895 tons VOC ≥ ∑n=1

i (Pi ) x (VOCi ) x [1−(capture x DRE )]2000 lbs / ton

−(Po ) x (VOCo)2000 lbs / ton

Where:

P i = usage of coating, or pan/cleanup solvent i in gallons for the last 12 months;

VOC i = volatile organic compound content of coating i, or pan/cleanup solvent i in pounds VOC per gallon;

P o = recovered pan/cleanup solvent o in gallons for the last 12 months;

VOC o = volatile organic compound content of pan/cleanup materials o in pounds of VOC per gallon;

Capture = the capture efficiency, assume 0%; and

DRE = destruction removal efficiency of any control device, 0% without controls.

d) Monitoring and/or Recordkeeping Requirements

(1) This facility shall maintain the following monthly records on all coatings and cleanup/pan solvents materials employed in this emissions unit:

a. the name or identification number of material employed, as applied;

b. the VOC content of each coating employed, minus water and exempt solvents, as applied;

c. the VOC content of each cleanup/pan solvent material employed;

d. the volume of each coating employed, in gallons;

e. the volume of each cleanup/pan solvent employed, in gallons;

f. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

g. the rolling, 12-month VOC emissions, in tons.

(2) If a credit for recovered cleanup/pan solvent material is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee

Page 59 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

shall maintain the following records for the recovered cleanup/pan solvent material, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) This facility shall, on an ongoing basis, evaluate the availability of an alternate coating and coating method that will reduce the emissions from this source and meet the coating specifications of the desired product. Should an alternate coating and/or coating method become available, as based on the Best Available Technology (BAT) for this type of operation, this facility shall submit a schedule for implementation of the alternate coatings and/or coating method within 30 days of the availability.

This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. The VOC content, in pounds per gallon;

b. The acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. The expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 60 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. The cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

Once the facility employs coatings in compliance with the requirements of OAC rule 3745-21-09(U)(1) in this source, the evaluation process of alternate coatings and the reporting requirement of this term will be discontinued.

(5) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(6) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air

Page 61 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable coatings VOC content of 5.36 pounds per gallon, minus water and exempt solvents, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 18.895 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average; and

e. the permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

(2) The permittee shall notify the Director (the Ohio EPA, Southwest District Office) in writing of any monthly record showing the use of noncomplying coatings and/or cleanup/pan solvent material. These notifications shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southwest District Office) within 30 days following the end of the calendar month.

(3) This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. the VOC content, in pounds per gallon;

b. the acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. the expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 62 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. the cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

VOC content of coatings shall not exceed 5.36 lbs VOC/gallon, minus water and exempt solvents, as applied.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the coatings. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:

Volatile Organic Compound (VOC) emissions from coatings and cleanup/pan solvents materials employed shall not exceed 18.895 tons VOC per rolling 12 month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be determined through the record keeping requirements as established in Section d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(5) of this permit.

d. Emission Limitation:

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

Page 63 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

0.71 lb/hr and 3.1 tons/yr NOx;

0.38 lb/hr and 1.67 tons/yr CO;

0.04 lb/hr and 0.15 ton/yr PM;

0.08 lb/hr and 0.34 ton/yr SO2; and

0.03 lb/hr and 0.11 ton/yr VOC.

Applicable Compliance Method:

Compliance with the limits for natural gas combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.4-1 and 1.4-2 (7/98). These emission factors (lb pollutant/mmscf) multiplied by the maximum hourly gas burning capacity of the burners (one at 1.75 mmBtu/hr, one at 1 mmBtu/hr, and six at 0.3125 mmBtu/hr) and times 1 scf/1000 Btu shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

Compliance with the limits for propane combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.5-1 (10/96) These emission factors (lb pollutant/1000 gallons) multiplied by the maximum hourly gas burning capacity of the burners (one at 1.75 mmBtu/hr, one at 1 mmBtu/hr, and six at 0.3125 mmBtu/hr) and divided by the 91.5 MMBtu/1000 gallons shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

e. Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

f. Emission Limitation;

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

g) Miscellaneous Requirements

(1) None.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

8. K033, B-Line Screen Presses

Operations, Property and/or Equipment Description:

Metal Decorative Coating Screen Press Printing Coating Line 173

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)f., and d)(6).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3)(PTI 05-06273)

VOC content of cleanup/pan solvent shall not exceed 7.76 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.62 lb/hr and 2.7 tons/yr NOx;0.33 lb/hr and 1.45 tons/yr CO;0.03 lb/hr and 0.13 ton/yr filterable PM;0.07 lb/hr and 0.30 ton/yr SO2; and0.02 lb/hr and 0.1 ton/yr VOC.

See Sections b)(2)b., c)(1), d)(1), d)(3), e)(1), f)(1)a., and f)(1)e., below.

c OAC rule 3745-31-05(D)Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c, d)(5), e)(1), and f)(d), below.

OAC rule 3745-31-05(F) The VOC emissions from coatings, pan, and cleanup materials shall not exceed 18.874 tons per rolling 12 month period.

See Sections c)(2), d)(1), e)(1), and f)(1)c., below.

Page 66 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

3745-21-09 (U)(2)(f)(ii) VOC content of coatings shall not exceed 5.21 lbs VOC/gallon, minus water and exempt solvents, as applied.

See Section b)(2)a., b)(2)d., d)(4), and e)(3), below.

d OAC rule 3745-17-10(B) 0.02 lbs of PE per mmBtu for drying oven.

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

e OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)f, below.f. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(6), below.

(2) Additional Terms and Conditions

a. Pursuant to OAC rule 3745-21-09(U)(2)(f)(ii), the best available technology has been determined to be extreme performance coatings that have a VOC content greater than the limitations of OAC rules 3745-21-09(U)(1)(c).

b. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

d. Extreme performance coatings are exempt by BAT determination in this permit and exemption under OAC rule 3745-21-09(U)(2)(f) in this permit from the requirements for extreme performance coatings in OAC rule 3745-21-09(U)(1). If at any time a non-extreme coating is used in this emissions unit, that coating must comply with the requirements of OAC rule 3745-21-09(U)(1).

Page 67 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

For the purpose of discontinuing the coating evaluation under section d)(4) of this permit, the VOC content of extreme performance coating used in this emissions unit shall not exceed 3.5 lbs of VOC per gallon, as applied, minus water and exempt solvents.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The weight of volatile organic materials applied/used for K033 shall not exceed 18.874 tons per rolling 12 months, calculated using the following formula:

18.874 tons VOC ≥ ∑n=1

i (Pi ) x (VOCi ) x [1−(capture x DRE )]2000 lbs / ton

−(Po ) x (VOCo)2000 lbs / ton

Where:

P i = usage of coating, or pan/cleanup solvent i in gallons for the last 12 months;

VOC i = volatile organic compound content of coating i, or pan/cleanup solvent i in pounds VOC per gallon;

P o = recovered pan/cleanup solvent o in gallons for the last 12 months;

VOC o = volatile organic compound content of pan/cleanup materials o in pounds of VOC per gallon;

Capture = the capture efficiency, assume 0%; and

DRE = destruction removal efficiency of any control device, 0% without controls.

d) Monitoring and/or Recordkeeping Requirements

(1) This facility shall maintain the following monthly records on all coatings and cleanup/pan solvents materials employed in this emissions unit:

a. the name or identification number of material employed, as applied;

b. the VOC content of each coating employed, minus water and exempt solvents, as applied;

c. the VOC content of each cleanup/pan solvent material employed;

d. the volume of each coating employed, in gallons;

e. the volume of each cleanup/pan solvent employed, in gallons;

f. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

g. the rolling, 12-month VOC emissions, in tons.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) If a credit for recovered cleanup/pan solvent material is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee shall maintain the following records for the recovered cleanup/pan solvent material, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) This facility shall, on an ongoing basis, evaluate the availability of an alternate coating and coating method that will reduce the emissions from this source and meet the coating specifications of the desired product. Should an alternate coating and/or coating method become available, as based on the Best Available Technology (BAT) for this type of operation, this facility shall submit a schedule for implementation of the alternate coatings and/or coating method within 30 days of the availability.

This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. The VOC content, in pounds per gallon;

b. The acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. The expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. The cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

Once the facility employs coatings in compliance with the requirements of OAC rule 3745-21-09(U)(1) in this source, the evaluation process of alternate coatings and the reporting requirement of this term will be discontinued.

(5) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calender months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calender months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(6) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable cleanup/pan solvent VOC content of 7.76 pounds per gallon, minus water and exempt solvents, as applied;

b. all exceedances of the rolling, 12-month VOC emission limitation of 18.874 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average; and

e. the permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

(2) The permittee shall notify the Director (the Ohio EPA, Southwest District Office) in writing of any monthly record showing the use of non-complying coatings and/or cleanup/pan solvent material. These notifications shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southwest District Office) within 30 days following the end of the calendar month.

(3) This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. the VOC content, in pounds per gallon;

b. the acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. the expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 71 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. the cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

VOC content of cleanup/pan solvent shall not exceed 7.76 lbs VOC/gallon.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the cleanup/pan solvent. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:

VOC content of coatings shall not exceed 5.21 lbs VOC/gallon, minus water and exempt solvents, as applied.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the coatings. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

c. Emission Limitation:

Volatile Organic Compound (VOC) emissions from coatings and cleanup/pan solvents materials employed shall not exceed 18.895 tons VOC per rolling 12 month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be determined through the record keeping requirements as established in Section d)(1) of this permit.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(5) of this permit.

e. Emission Limitation:

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.62 lb/hr and 2.7 tons/yr NOx;

0.33 lb/hr and 1.45 tons/yr CO;

0.03 lb/hr and 0.13 ton/yr PE;

0.07 lb/hr and 0.30 ton/yr SO2; and

0.02 lb/hr and 0.1 ton/yr VOC.

Applicable Compliance Method:

Compliance with the limits for natural gas combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.4-1 and 1.4-2 (7/98). These emission factors (lb pollutant/mmscf) multiplied by the maximum hourly gas burning capacity of the burners (one at 0.78125 mmBtu/hr, two at 1 mmBtu/hr, and four at 0.3125 mmBtu/hr) and times 1 scf/1020 Btu shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

Compliance with the limits for propane combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.5-1 (10/96) These emission factors (lb pollutant/1000 gallons) multiplied by the maximum hourly gas burning capacity of the burners (one at 0.78125 mmBtu/hr, two at 1 mmBtu/hr, and four at 0.3125 mmBtu/hr) and divided by the 91.5 MMBtu/1000 gallons shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

f. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/restoration solvent material.

g) Miscellaneous Requirements

(1) None.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

9. K045, Roll Coater; Department 347

Operations, Property and/or Equipment Description:

one coating line (dept. 184); coat metal decorated products

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(6).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3)(PTI 05-07329)

VOC content of cleanup/pan solvent shall not exceed 7.76 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.57 lb/hr and 2.51 tons/yr NOx;0.31 lb/hr and 1.35 tons/yr CO;0.03 lb/hr and 0.12 ton/yr filterable PM;0.06 lb/hr and 0.28 ton/yr SO2; and0.02 lb/hr and 0.09 ton/yr VOC.

See Sections b)(2)b., c)(1), d)(1), d)(3), e)(1), f)(1)a., and f)(1)e., below.

b. OAC rule 3745-31-05(D)Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c, d)(5), e)(1), and f)(d), below.

c. OAC rule 3745-31-05(F) The VOC emissions from coatings, pan, and cleanup materials shall not exceed 22.8 tons per rolling 12 month period.

See Sections c)(2), d)(1), e)(1), and f)(1)c., below.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

d. OAC rule 3745-21-09 (U)(2)(f)(ii) VOC content of coatings shall not exceed 5.36 lbs VOC/gallon, minus water and exempt solvents, as applied.

See Section b)(2)a., b)(2)d., d)(4), and e)(3), below.

e. OAC rule 3745-17-10(B) 0.02 lbs of PE per mmBtu for drying oven.

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)f, below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(6), below.

(1) Additional Terms and Conditions

a. Pursuant to OAC rule 3745-21-09(U)(2)(f)(ii), the best available technology has been determined to be extreme performance coatings that have a VOC content greater than the limitations of OAC rules 3745-21-09(U)(1)(c).

b. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

d. Extreme performance coatings are exempt by BAT determination in this permit and exemption under OAC rule 3745-21-09(U)(2)(f) in this permit from the requirements for extreme performance coatings in OAC rule 3745-21-09(U)(1). If at any time a non-extreme coating is used in this emissions unit, that coating must comply with the requirements of OAC rule 3745-21-09(U)(1).

Page 76 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

For the purpose of discontinuing the coating evaluation under section d)(4) of this permit, the VOC content of extreme performance coating used in this emissions unit shall not exceed 3.5 lbs of VOC per gallon, as applied, minus water and exempt solvents.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The weight of volatile organic materials applied/used for K045 shall not exceed 22.8 tons per rolling 12 months, calculated using the following formula:

22.8 tons VOC ≥ ∑n=1

i (Pi ) x (VOCi ) x [1−(capture x DRE )]2000 lbs / ton

−(Po ) x (VOCo)2000 lbs / ton

Where:

P i = usage of coating, or pan/cleanup solvent i in gallons for the last 12 months;

VOC i = volatile organic compound content of coating i, or pan/cleanup solvent i in pounds VOC per gallon;

P o = recovered pan/cleanup solvent o in gallons for the last 12 months;

VOC o = volatile organic compound content of pan/cleanup materials o in pounds of VOC per gallon;

Capture = the capture efficiency, assume 0%; and

DRE = destruction removal efficiency of any control device, 0% without controls.

d) Monitoring and/or Recordkeeping Requirements

(1) This facility shall maintain the following monthly records on all coatings and cleanup/pan solvents materials employed in this emissions unit:

a. the name or identification number of material employed, as applied;

b. the VOC content of each coating employed, minus water and exempt solvents, as applied;

c. the VOC content of each cleanup/pan solvent material employed;

d. the volume of each coating employed, in gallons;

e. the volume of each cleanup/pan solvent employed, in gallons;

f. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

g. the rolling, 12-month VOC emissions, in tons.

Page 77 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) If a credit for recovered cleanup/pan solvent material is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee shall maintain the following records for the recovered cleanup/pan solvent material, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) This facility shall, on an ongoing basis, evaluate the availability of an alternate coating and coating method that will reduce the emissions from this source and meet the coating specifications of the desired product. Should an alternate coating and/or coating method become available, as based on the Best Available Technology (BAT) for this type of operation, this facility shall submit a schedule for implementation of the alternate coatings and/or coating method within 30 days of the availability.

This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. The VOC content, in pounds per gallon;

b. The acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. The expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 78 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. The cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

Once the facility employs coatings in compliance with the requirements of OAC rule 3745-21-09(U)(1) in this source, the evaluation process of alternate coatings and the reporting requirement of this term will be discontinued.

(5) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(6) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air

Page 79 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable cleanup/pan solvent VOC content of 7.76 pounds per gallon;

b. all exceedances of the rolling, 12-month VOC emission limitation of 22.8 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average; and

e. the permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

(2) The permittee shall notify the Director (the Ohio EPA, Southwest District Office) in writing of any monthly record showing the use of non-complying coatings and/or cleanup/pan solvent material. These notifications shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southwest District Office) within 30 days following the end of the calendar month.

(3) This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. the VOC content, in pounds per gallon;

b. the acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. the expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 80 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. the cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

VOC content of cleanup/pan solvent shall not exceed 7.76 lbs VOC/gallon.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the cleanup/pan solvent. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:

VOC content of coatings shall not exceed 5.36 lbs VOC/gallon, minus water and exempt solvents, as applied.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the coatings. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

c. Emission Limitation:

Volatile Organic Compound (VOC) emissions from coatings and cleanup/pan solvents materials employed shall not exceed 22.8 tons VOC per rolling 12 month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be determined through the record keeping requirements as established in Section d)(1) of this permit.

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Page 81 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(5) of this permit.

e. Emission Limitation:

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

0.57 lb/hr and 2.51 tons/yr NOx;

0.31 lb/hr and 1.35 tons/yr CO;

0.03 lb/hr and 0.12 ton/yr PE;

0.06 lb/hr and 0.28 ton/yr SO2; and

0.02 lb/hr and 0.09 ton/yr VOC.

Applicable Compliance Method:

Compliance with the limits for natural gas combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.4-1 and 1.4-2 (7/98). These emission factors (lb pollutant/mmscf) multiplied by the maximum hourly gas burning capacity of the burners (one at 1.75 mmBtu/hr, one at 1 mmBtu/hr, and six at 0.3125 mmBtu/hr) and times 1 scf/1020 Btu shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

Compliance with the limits for propane combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.5-1 (10/96) These emission factors (lb pollutant/1000 gallons) multiplied by the maximum hourly gas burning capacity of the burners (one at 1.75 mmBtu/hr, one at 1 mmBtu/hr, and six at 0.3125 mmBtu/hr) and divided by the 91.5 MMBtu/1000 gallons shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

f. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Page 82 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/pan solvent material.

g) Miscellaneous Requirements

(1) None.

Page 83 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

10. K046, E-coat Line

Operations, Property and/or Equipment Description:

Electrodeposition surface coating of miscellaneous metal parts

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(4).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3) (PTI 05-14394)

The Volatile Organic Compounds (VOC) content of replenishment material used in this emissions unit shall not exceed 0.19 lb/gallon, as applied

The VOC content of cleanup materials employed on this emission unit shall not exceed 0.68 lb VOC/lb cleanup material

The emissions from natural gas combustion in the drying ovens shall not exceed the following:

0.429 lb/hr and 1.88 tons/yr NOx;0.36 lb/hr and 1.58 tons/yr CO;0.033 lb/hr and 0.14 ton/yr filterable PM;0.003 lb/hr and 0.01 ton/yr SO2; and0.024 lb/hr and 0.1 ton/yr VOC.

See Sections b)(2)a., b)(2)b., c)(1), d)(1), d)(2), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)

(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(3), e)(1), and f)(1)d., below.

Page 84 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

c. OAC rule 3745-31-05(F) The maximum replenishment material usage for this emissions unit shall not exceed 100,000 gallons per rolling 12-month period.

The maximum cleanup material usage for this emissions unit shall not exceed 150 gallons per rolling 12-month period.

Emissions of VOC excluding oven emissions shall not exceed 9.93 tons per rolling 12-month period.

See Section d)(1), e)(1, and f)(1)c., belowd. OAC rule 3745-21-09(U) See Section b)(2)b., below.e. OAC rule 3745-17-07(A)

(for the drying ovens)The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)e, below.f. OAC rule 3745-17-11(B)

(for the drying ovens)0.02 lbs PE per mmBtu for drying oven

See Sections b)(2)a, c)(1), d)(2), e)(1), and f)(1)f, below.

g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(4), below.

(2) Additional Terms and Conditions

a. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

b. This limitation for the coating, calculates to 0.64 lb VOC per gallon of coating minus water and exempt solvents, and is more stringent than the limits found in OAC rule 3745-21-09(U).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

Page 85 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) The permittee shall burn only natural gas in this emissions unit.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall collect and record the following information each month for this emissions unit:

a. the name and identification number of each coating, and cleanup material, as applied;

b. the VOC content of each coating, as applied;

c. the VOC content of each cleanup material employed;

d. the volume in gallons of each coating employed;

e. the volume in gallons of each cleanup material employed;

f. the monthly VOC emissions from the coatings, and cleanup materials employed, i.e., multiply the monthly volume, in gallons, of each coating and cleanup/pan solvent material employed by its respective VOC content, and summarize the results;

g. the rolling, 12 month usage summation for coatings, and cleanup materials employed; and

h. the rolling, 12 month summation of VOC emissions from the coating, and cleanup material employed, prior to any credit for recovered materials.

(2) For each day during which the permittee burns fuel other than natural gas in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(3) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

Page 86 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(4) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable cleanup solvent VOC content of 0.68 pounds per gallon, as applied;

b. all exceedances of allowable replenishment material usage of 100,000 gallons per rolling 12-month period;

c. all exceedances of allowable cleanup material usage of 150 gallons per rolling 12-month period;

d. all exceedances of the rolling, 12-month VOC emission limitation of 9.93 tons;

e. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

Page 87 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

f. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average; and

g. the permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

(2) The permittee shall notify the Director (the Ohio EPA, Southwest District Office) in writing of any monthly record showing the use of non-complying coatings. These notifications shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southwest District Office) within 30 days following the end of the calendar month.

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitations:

The VOC content of replenishment material used in this emissions unit shall not exceed 0.19 lb/gallon.

The VOC content of cleanup materials employed on this emission unit shall not exceed 0.68 lb VOC/lb of cleanup material

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the coatings and cleanup materials. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

b. The emissions from natural gas combustion in the drying ovens shall not exceed the following:

0.429 lb/hr and 1.88 tons/yr NOx;

0.36 lb/hr and 1.58 tons/yr CO;

0.033 lb/hr and 0.14 ton/yr filterable PM;

0.003 lb/hr and 0.01 ton/yr SO2; and

0.024 lb/hr and 0.1 ton/yr VOC.

Applicable Compliance Method:

Page 88 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the limits for natural gas combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.4-1 and 1.4-2 (7/98). These emission factors (lb pollutant/10 mmscf) multiplied by the maximum hourly gas burning capacity of the burners (4.375 mmBtu) and times 1 scf/1020 00 Btu shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

c. Emission Limitation:

Emissions of VOC excluding oven emissions shall not exceed 9.93 tons per rolling 12-month period.

The above emissions limitation was established based on the following equation:

AER=∑ [ (Pi ) x (VOCi ) ] x [1− (Capture x DRE )]2000

Where:

AER = Annual emission rate, in tons;

P = usage of each coating or cleanup material in gallons;

VOC = volatile organic compound content of each coating or cleanup material in pounds VOC per gallon;

capture = the capture efficiency, assumed to be 0%; and

DRE = destruction removal efficiency of any control device, 0% without controls.

Applicable Compliance Method:

Compliance shall be assumed so long as the permittee does not exceed the VOC content limitations for both coatings (0.19 lb/gallon) and cleanup materials (0.68 lb/lb of cleanup material), nor the usage limitations for coatings (100,000 gallons) and cleanup materials ( 150 gallons). Compliance may also be demonstrated through the following calculation:

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Page 89 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(3) of this permit.

e. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

f. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/pan solvent material.

g) Miscellaneous Requirements

(1) None.

Page 90 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

11. K048, Dept 350

Operations, Property and/or Equipment Description:

Department 350 printing/coating line; coat metal decorated products

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)g., and d)(6).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(A)(3)(PTI 05-13963)

VOC content of cleanup/pan solvent shall not exceed 7.76 pounds per gallon.

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

2.12 lb/hr and 9.28 tons/yr NOx;1.14 lb/hr and 5.0 tons/yr CO;0.11 lb/hr and 0.46 ton/yr filterable PM;0.24 lb/hr and 01.02 ton/yr SO2; and0.08 lb/hr and 0.34 ton/yr VOC.

See Sections b)(2)b., c)(1), d)(1), d)(3), e)(1), f)(1)a., and f)(1)e., below.

b. OAC rule 3745-31-05(D)Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c, d)(5), e)(1), and f)(d), below.

c. OAC rule 3745-31-05(F) The VOC emissions from coatings, pan, and cleanup materials shall not exceed 27.8 tons per rolling 12 month period.

See Sections c)(2), d)(1), e)(1), and f)(1)c., below.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

d. OAC rule 3745-21-09 (U)(2)(f)(ii) VOC content of coatings shall not exceed 5.21 lbs VOC/gallon, minus water and exempt solvents, as applied.

See Section b)(2)a., b)(2)d., d)(4), and e)(3), below.

e. OAC rule 3745-17-10(B) 0.02 lbs of PE per mmBtu for drying oven.

See Sections c)(1), d)(3), e)(1), and f)(1)g., below.

f. OAC rule 3745-17-07(A)(for the drying ovens)

The Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

See Section f)(1)f, below.g. OAC rule 3745-114-01 Ohio Toxic Rule

See Section d)(6), below.

(2) Additional Terms and Conditions

a. Pursuant to OAC rule 3745-21-09(U)(2)(f)(ii), the best available technology has been determined to be extreme performance coatings that have a VOC content greater than the limitations of OAC rules 3745-21-09(U)(1)(c).

b. The emission limitations for PM10, SO2, NOx, CO and VOC from the combustion of natural gas and/or propane in the drying ovens are established to reflect potentials to emit for this emissions unit. Therefore, no additional monitoring, record keeping and/or reporting requirements are necessary to ensure compliance with these limitations.

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

d. Extreme performance coatings are exempt by BAT determination in this permit and exemption under OAC rule 3745-21-09(U)(2)(f) in this permit from the requirements for extreme performance coatings in OAC rule 3745-21-09(U)(1). If at any time a non-extreme coating is used in this emissions unit, that coating must comply with the requirements of OAC rule 3745-21-09(U)(1).

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

For the purpose of discontinuing the coating evaluation under section d)(4) of this permit, the VOC content of extreme performance coating used in this emissions unit shall not exceed 3.5 lbs of VOC per gallon, as applied, minus water and exempt solvents.

c) Operational Restrictions

(1) The permittee shall burn only natural gas and/or propane as fuel in this emissions unit.

(2) The weight of volatile organic materials applied/used for K045 shall not exceed 27.8 tons per rolling 12 months, calculated using the following formula:

27.8 tons VOC ≥ ∑n=1

i (Pi ) x (VOCi ) x [1−(capture x DRE )]2000 lbs / ton

−(Po ) x (VOCo)2000 lbs / ton

Where:

P i = usage of coating, or pan/cleanup solvent i in gallons for the last 12 months;

VOC i = volatile organic compound content of coating i, or pan/cleanup solvent i in pounds VOC per gallon;

P o = recovered pan/cleanup solvent o in gallons for the last 12 months;

VOC o = volatile organic compound content of pan/cleanup materials o in pounds of VOC per gallon;

Capture = the capture efficiency, assume 0%; and

DRE = destruction removal efficiency of any control device, 0% without controls.

d) Monitoring and/or Recordkeeping Requirements

(1) This facility shall maintain the following monthly records on all coatings and cleanup/pan solvents materials employed in this emissions unit:

a. the name or identification number of material employed, as applied;

b. the VOC content of each coating employed, minus water and exempt solvents, as applied;

c. the VOC content of each cleanup/pan solvent material employed;

d. the volume of each coating employed, in gallons;

e. the volume of each cleanup/pan solvent employed, in gallons;

f. the VOC emissions, in tons, as determined by the equation in Section c)(2) of these terms and conditions; and

g. the rolling, 12-month VOC emissions, in tons.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) If a credit for recovered cleanup/pan solvent material is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee shall maintain the following records for the recovered cleanup/pan solvent material, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) For each day during which the permittee burns fuel other than natural gas or propane in this emissions unit, the permittee shall maintain a record of the type and quantity of fuel burned.

(4) This facility shall, on an ongoing basis, evaluate the availability of an alternate coating and coating method that will reduce the emissions from this source and meet the coating specifications of the desired product. Should an alternate coating and/or coating method become available, as based on the Best Available Technology (BAT) for this type of operation, this facility shall submit a schedule for implementation of the alternate coatings and/or coating method within 30 days of the availability.

This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. The VOC content, in pounds per gallon;

b. The acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. The expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 94 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. The cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

Once the facility employs coatings in compliance with the requirements of OAC rule 3745-21-09(U)(1) in this source, the evaluation process of alternate coatings and the reporting requirement of this term will be discontinued.

(5) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

*A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(6) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air

Page 95 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. all exceedances of the maximum allowable cleanup/pan solvent VOC content of 7.76 pounds per gallon;

b. all exceedances of the rolling, 12-month VOC emission limitation of 27.8 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average; and

e. the permittee shall notify the Director (the Ohio EPA, Southwest District Office) of any record showing the use of a fuel other than natural gas or propane in this emissions unit.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

(2) The permittee shall notify the Director (the Ohio EPA, Southwest District Office) in writing of any monthly record showing the use of non-complying coatings and/or cleanup/pan solvent material. These notifications shall include a copy of such record and shall be sent to the Director (the Ohio EPA, Southwest District Office) within 30 days following the end of the calendar month.

(3) This facility shall submit quarterly reports that summarize the evaluation of an alternate coating and coating method which details the following information for each coating and/or coating method evaluated:

a. the VOC content, in pounds per gallon;

b. the acceptability;

c. the reason why the alternative coating does not meet specification, for unacceptable coatings;

d. the expected reduction in VOC emissions from the utilization of the acceptable alternate coatings; and

Page 96 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. the cost of modifying the source to utilize the alternate coatings and/or coating method.

These reports shall be submitted by February 15, May 15, August 15, and November 15 of each year and shall cover the previous calendar quarter (October through December, January through March, April through June, and July through September, respectively).

f) Testing Requirements

(1) Compliance with the emission limitation(s) in b)(1) of these terms and conditions shall be determined in accordance with the following method(s):

a. Emission Limitation:

VOC content of cleanup/pan solvent shall not exceed 7.76 lbs VOC/gallon.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the cleanup/pan solvent. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:

VOC content of coatings shall not exceed 5.21 lbs VOC/gallon, minus water and exempt solvents, as applied.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the coatings. The record keeping requirements contained in Section d)(1) shall demonstrate that only materials with these VOC content limitations are applied.

c. Emission Limitation:

Volatile Organic Compound (VOC) emissions from coatings and cleanup/pan solvents materials employed shall not exceed 27.8 tons VOC per rolling 12 month period.

Applicable Compliance Method:

Compliance with the annual allowable VOC emission limitation above shall be determined through the record keeping requirements as established in Section d)(1) of this permit.

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(5) of this permit.

e. Emission Limitation:

The emissions from natural gas and propane combustion in the drying ovens shall not exceed the following:

2.12 lb/hr and 9.28 tons/yr NOx;

1.14 lb/hr and 5.0 tons/yr CO;

0.11 lb/hr and 0.46 ton/yr PE;

0.24 lb/hr and 1.02 ton/yr SO2; and

0.08 lb/hr and 0.34 ton/yr VOC.

Applicable Compliance Method:

Compliance with the limits for natural gas combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.4-1 and 1.4-2 (7/98). These emission factors (lb pollutant/mmscf) multiplied by the maximum hourly gas burning capacity of the burners (one at 2.5 mmBtu/hr, two at 3.75 mmBtu/hr, one at 3.4375 mmBtu/hr, and one at 0.4 mmBtu/hr) and times 1 scf/1020 Btu shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

Compliance with the limits for propane combustion within the drying ovens shall be based upon the emission factors from AP-42 "Compilation of Air Pollutant Emission Factors", Tables 1.5-1 (10/96) These emission factors (lb pollutant/1000 gallons) multiplied by the maximum hourly gas burning capacity of the burners (one at 2.5 mmBtu/hr, two at 3.75 mmBtu/hr, one at 3.4375 mmBtu/hr, and one at 0.4 mmBtu/hr) and divided by the 91.5 MMBtu/1000 gallons shall be the demonstration of compliance with the hourly limits. Compliance with the ton per year limits are documented by multiplying the calculated hourly limits by 8760 hours in a year and dividing by 2000 pounds.

f. Emission Limitation:

Visible PE from any stack shall not exceed 20 percent opacity, as a six-minute average, except as specified by rule.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance shall be determined through visible emission observations performed in accordance with 40 CFR Part 60, Appendix A, Method 9 and the procedures specified in OAC rule 3745-17-03(B)(1).

g. Emission Limitation: Emission Limitation:

0.02 lbs PE per mmBtu for drying oven

Applicable Compliance Method:

Compliance with this limit shall be based upon the requirement for burning only natural gas or propane for this emissions unit.

If required, the permittee shall demonstrate compliance with this emissions limitation through a compliance demonstration performed in accordance with 40 CFR Part 60, Appendix A, Method 1 thru 5.

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each coating and cleanup/pan solvent material.

g) Miscellaneous Requirements

(1) None.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

12. P081, Stamping Press 1-269

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

Page 103 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Page 104 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 105 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

13. P082, Stamping Press 1-082

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

Page 106 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Page 107 of 452

Page 116: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

Page 108 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

Page 109 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Page 110 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements:

(1) None.

Page 111 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

14. P085, Stamping Press 1-213

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

Page 112 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Page 113 of 452

Page 122: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

Page 114 of 452

Page 123: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

Page 115 of 452

Page 124: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Page 116 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 117 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

15. P086, Stamping Press 1-247

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 118 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 119 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 120 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 121 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 122 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 123 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

16. P087, Stamping Press 1-087

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 124 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 125 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 126 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 127 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 128 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 129 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

17. P088, Stamping Press 1-088

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 130 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 131 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 132 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 133 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 134 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 135 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

18. P089, Stamping Press 1-248

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 136 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 137 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 138 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 139 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 140 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 141 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

19. P090, Stamping Press 1-249

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 142 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 143 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 144 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 145 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 146 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 147 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

20. P091, Stamping Press 1-091

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 148 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 149 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 150 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 151 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 152 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 153 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

21. P092, Stamping Press 1-251

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 154 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 155 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 156 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 157 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 158 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 159 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

22. P093, Stamping Press 1-252

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 160 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 161 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 162 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 163 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 164 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 165 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

23. P094, Stamping Press 1-253

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 166 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 167 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 168 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 169 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 170 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 171 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

24. P095, Stamping Press 1-272

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 172 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 173 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 174 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 175 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 176 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 177 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

25. P096, Stamping Press 1- 276

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 178 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 179 of 452

Page 188: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 180 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 181 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 182 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 183 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

26. P097, Stamping Press 1- 278

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 184 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 185 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 186 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 187 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 188 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 189 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

27. P098, Stamping Press 1-279

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 190 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 191 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 192 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 195 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

28. P099, Stamping Press 1-280

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 197 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 198 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 199 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 200 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 201 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

29. P100, Stamping Press 1-286

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 202 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 203 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 204 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 207 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

30. P101, Stamping Press 1-291

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 208 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 209 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 210 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 211 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 212 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 213 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

31. P102, Stamping Press 1-292

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 214 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 215 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 216 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 217 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 219 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

32. P103, Stamping Press 1-293

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 220 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 221 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 222 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 223 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 224 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 225 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

33. P104, Stamping Press 1-299

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 226 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 227 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 228 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 229 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 230 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 231 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

34. P105, Rollformer 7-141

Operations, Property and/or Equipment Description:

Rollformer 7-141

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 232 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 233 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 234 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 235 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 236 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 237 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

35. P106, Rollformer 7-240

Operations, Property and/or Equipment Description:

Rollformer 7-240

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13323)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 6.76 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 238 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P080 through P106 combined shall not exceed 48.02 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i48.02 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 6.76 lbs VOC/gallon

Page 239 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units P080 through P106 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P080 through P106, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 240 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 6.76 lbs/gallon;

Page 241 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 48.02 tons for emissions units P081 through P106, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

6.76 lbs VOC/gallon of lubricating oils Type 1

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 48.02 tons as a rolling, 12-month summation for emissions units P081 through P106, inclusive.

Applicable Compliance Method:

Page 242 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 243 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

36. P107, Stamping Press 1-261

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 244 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 245 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 246 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

Page 247 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 248 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 249 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

37. P108, Stamping Press 1-266

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 250 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 251 of 452

Page 260: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 252 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

Page 253 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 254 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements

(1) None.

Page 255 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

38. P109, Stamping Press 1-267

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 256 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 257 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 258 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 260 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 261 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

39. P110, Stamping Press 1-290

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 262 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 263 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 264 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

Page 265 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 266 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 267 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

40. P111, Stamping Press 1-301

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 268 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 269 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 270 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

Page 271 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 272 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 273 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

41. P112, Stamping Press 1-302

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 274 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 275 of 452

Page 284: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 276 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

Page 277 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 278 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 279 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

42. P113, Stamping Press 1-227

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

Page 280 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 281 of 452

Page 290: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 282 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of Type 1 lubricating oils employed exceeds 5.75 lbs/gallon;

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 285 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

43. P114, Stamping Press 1-237

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13345)

The volatile organic compound (VOC) content of lubricating oils shall not exceed 5.75 pounds per gallon.

See Sections c)(1), c)(2), d)(1), e)(1), f)(1)a., and f)(1)b., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

Page 287 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

Page 288 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the VOC content of lubricating oils employed exceeds 5.75 lbs/gallon;

Page 289 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

b. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. VOC Content Limitation:

5.75 lbs VOC/gallon of lubricating oils

Applicable Compliance Method:

Compliance with this limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

Formulation data or USEPA Method 24 shall be used to determine the volatile organic compound content of materials added to this emissions unit.

b. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Page 290 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

c. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

d. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 291 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

44. P115, Screen Washer A

Operations, Property and/or Equipment Description:

Screen Washer using solvent cleaner

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(4).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13943)

The volatile organic compound (VOC) content of the cleaning solution shall not exceed 8.5 lbs VOC/gallon.

See Section d)(1), e)(1), and f)(1)a., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. as based on a rolling, 12-month summation.

See Sections b)(2)c., d)(3), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) VOC emissions from emission units P115 and P116 combined shall not exceed 40.0 tons per rolling 12-month period.

See Section d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(5), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 Ohio Toxic Rule

See Sections d)(4), below.

Page 292 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) None.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P115 and P116, combined:

a. the company name or identification for each cleaning solution employed;

b. the volume, in gallons, of each cleaning solution employed;

Page 293 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. the VOC content of each cleaning solution employed, in pounds per gallon;

d. the rolling 12-month summation of VOC emissions from the cleaning solution employed, prior to any credit claimed for solvent recycling i.e., the sum of the usage of each cleaning solution employed multiplied by its respective VOC content.

(2) If a credit for recovered cleaning solution is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee shall maintain the following records for the recovered cleaning solution, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. a record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

Page 294 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(4) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(5) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

Page 295 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the volatile organic compound (VOC) content of the cleaning solution exceeded 8.5 lbs VOC/gallon;

b. The permittee shall submit deviation (excursion) reports which identify all exceedances of the rolling, 12-month limitation upon VOC emissions for emission units P115 and P116 combined of 40 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in Section b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The volatile organic compound (VOC) content of the cleaning solution shall not exceed 8.5 lbs VOC/gallon.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the cleaning solutions. The record keeping requirements contained in d)(1). shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:Page 296 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

VOC emissions from emission units P115 and P116 combined shall not exceed 40.0 tons per rolling 12-month period.

Equation:

[Sum of all (Vi)(Gi)] ÷ 2000 lbs/Ton] - [(Rw)(Po)(VOCo)÷ 2000 lbs/Ton]

where

Vi = VOC content in pounds per gallon of each cleaning solution, subject to the following limitation: Vi 8.5 lbs VOC/gallon;

Gi = Gallons used of each cleaning solution for the rolling 12 month period;

Rw = ratio of solvent used on Emission units P115 and P116 to (total solvent used on all Emission units - the amount of solvent used on Emission unit K045);

Po = total gallons of recovered solvents less the gallons of solvent recovered from Emission unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d) of this permit.

c. Emission Limitation:

VOC emissions from these emissions units shall not exceed 40.0 tons per rolling 12-month period.

Applicable Compliance Method:

Compliance with this limitation shall be based upon compliance with the grouped annual limit for P115 and P116.

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

Page 297 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each solvent containing material.

g) Miscellaneous Requirements

(1) None.

Page 298 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

45. P116, Screen Washer B

Operations, Property and/or Equipment Description:

Screen Washer using solvent cleaner

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)e., and d)(4).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC Rule 3745-31-05(A)(3)(PTI 05-13943)

The volatile organic compound (VOC) content of the cleaning solution shall not exceed 8.5 lbs VOC/gallon.

See Section d)(1), e)(1), and f)(1)a., below.

b. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. as based on a rolling, 12-month summation.

See Sections b)(2)c., d)(3), e)(1), and f)(1)d., below.

c. OAC rule 3745-31-05(F) VOC emissions from emission units P115 and P116 combined shall not exceed 40.0 tons per rolling 12-month period.

See Section d)(1), e)(1), and f)(1)c., below.

d. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(5), e)(1), and f)(1)e., below.

e. OAC rule 3745-114-01 Ohio Toxic Rule

See Sections d)(4), below.

Page 299 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) None.

d) Monitoring and/or Recordkeeping Requirements

(1) The permittee shall maintain monthly records of the following information for emissions units P115 and P116, combined:

a. the company name or identification for each cleaning solution employed;

b. the volume, in gallons, of each cleaning solution employed;

Page 300 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. the VOC content of each cleaning solution employed, in pounds per gallon;

d. the rolling 12-month summation of VOC emissions from the cleaning solution employed, prior to any credit claimed for solvent recycling i.e., the sum of the usage of each cleaning solution employed multiplied by its respective VOC content.

(2) If a credit for recovered cleaning solution is used to demonstrate compliance and/or used in the calculation of rolling, 12 month emission calculations, the permittee shall maintain the following records for the recovered cleaning solution, and the recovery drum or tank serving this emissions unit:

a. the date recovered materials were first added to the recovery tank/drum and the date the materials from the recovery drum or tank were shipped off site;

b. the total amount of material collected and shipped for recycle/recovery and/or disposal at an outside facility, in gallons, on the day it is shipped;

c. a record of the VOC content of each cleanup/pan solvent material that is collected for recovery, in pounds per gallon, or a record of the testing results of the VOC content of the material shipped;

d. the mass (lbs) of VOC to be credited to the rolling, 12 month emissions summation, from each shipment of recovered material, calculated using the lowest VOC content of any cleanup/pan solvent material recovered, unless a higher VOC content is established from the testing results of the recovered material shipped (i.e., b x c), and the date of each such shipment or record of credit; and

e. the record of the total amount of VOC emissions (lbs or tons) that may be applied as a credit, for the materials shipped for recycle/recovery and/or disposal at an outside facility, summed from the records of the VOC emission credits (d), for each shipment recorded during the rolling 12 month period.

(3) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

Page 301 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(4) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(5) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

Page 302 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing the volatile organic compound (VOC) content of the cleaning solution exceeded 8.5 lbs VOC/gallon;

b. The permittee shall submit deviation (excursion) reports which identify all exceedances of the rolling, 12-month limitation upon VOC emissions for emission units P115 and P116 combined of 40 tons;

c. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average;

d. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

e. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

f. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in Section b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The volatile organic compound (VOC) content of the cleaning solution shall not exceed 8.5 lbs VOC/gallon.

Applicable Compliance Method:

Formulation data or USEPA Method 24 shall be used to determine the VOC content of the cleaning solutions. The record keeping requirements contained in d)(1). shall demonstrate that only materials with these VOC content limitations are applied.

b. Emission Limitation:Page 303 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

VOC emissions from emission units P115 and P116 combined shall not exceed 40.0 tons per rolling 12-month period.

Equation:

[Sum of all (Vi)(Gi)] ÷ 2000 lbs/Ton] - [(Rw)(Po)(VOCo)÷ 2000 lbs/Ton]

where

Vi = VOC content in pounds per gallon of each cleaning solution, subject to the following limitation: Vi 8.5 lbs VOC/gallon;

Gi = Gallons used of each cleaning solution for the rolling 12 month period;

Rw = ratio of solvent used on Emission units P115 and P116 to (total solvent used on all Emission units - the amount of solvent used on Emission unit K045);

Po = total gallons of recovered solvents less the gallons of solvent recovered from Emission unit K045, for the subject time period; and

VOCo = VOC content of recovered solvents in pounds of VOC per gallon

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d) of this permit.

c. Emission Limitation:

VOC emissions from these emissions units shall not exceed 40.0 tons per rolling 12-month period.

Applicable Compliance Method:

Compliance with this limitation shall be based upon compliance with the grouped annual limit for P115 and P116.

d. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

Page 304 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

e. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each solvent containing material.

g) Miscellaneous Requirements

(1) None.

Page 305 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

46. P117, Stamping Press 1-001

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 306 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 307 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 308 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 309 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 310 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 311 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

47. P118, Stamping Press 1-002

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 312 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 313 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 314 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 315 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 316 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 317 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

48. P119, Stamping Press 1-003

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 318 of 452

Page 327: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 319 of 452

Page 328: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 320 of 452

Page 329: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 321 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 322 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 323 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

49. P120, Stamping Press 1-014

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 324 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 325 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 326 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 327 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 328 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None

Page 329 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

50. P121, Stamping Press 1-025

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 330 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 331 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 332 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 333 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 334 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 335 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

51. P122, Stamping Press 1-026

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 336 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 337 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 338 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 339 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 340 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 341 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

52. P123, Stamping Press 1-034

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 342 of 452

Page 351: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 343 of 452

Page 352: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 344 of 452

Page 353: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 345 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 346 of 452

Page 355: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 347 of 452

Page 356: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

53. P124, Stamping Press 1-048

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 348 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 349 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 350 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 351 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 352 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 353 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

54. P125, Stamping Press 1-052

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 354 of 452

Page 363: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 355 of 452

Page 364: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 356 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 357 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 358 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 359 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

55. P126, Stamping Press 1-81

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 360 of 452

Page 369: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 361 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 362 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 363 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 364 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 365 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

56. P127, Stamping Press 1-89

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 366 of 452

Page 375: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 367 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 368 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 369 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 370 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 371 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

57. P128, Stamping Press 1-90

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 372 of 452

Page 381: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 373 of 452

Page 382: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 374 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 375 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 376 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 377 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

58. P129, Stamping Press 1-92

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 378 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 379 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 380 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 381 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 382 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 383 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

59. P130, Stamping Press 1-93

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 384 of 452

Page 393: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 385 of 452

Page 394: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 386 of 452

Page 395: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 387 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 388 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 389 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

60. P131, Stamping Press 1-126

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 390 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 391 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 392 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 393 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 394 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 395 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

61. P132, Stamping Press 1-127

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 396 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 397 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 398 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 399 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 400 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 401 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

62. P133, Stamping Press 1-128

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 402 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 403 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 404 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 405 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 406 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 407 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

63. P134, Stamping Press 1-129

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 408 of 452

Page 417: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 409 of 452

Page 418: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 410 of 452

Page 419: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 411 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 412 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 413 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

64. P135, Stamping Press 1-131

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 414 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 415 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 416 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 417 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 418 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 419 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

65. P136, Stamping Press 1-132

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 420 of 452

Page 429: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 421 of 452

Page 430: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 422 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 423 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 424 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 425 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

66. P137, Stamping Press 1-133

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 426 of 452

Page 435: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 427 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 428 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 429 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 430 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 431 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

67. P138, Stamping Press 1-138

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 432 of 452

Page 441: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 433 of 452

Page 442: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 434 of 452

Page 443: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 435 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 436 of 452

Page 445: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 437 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

68. P139, Stamping Press 1-214

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 438 of 452

Page 447: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 439 of 452

Page 448: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 440 of 452

Page 449: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 441 of 452

Page 450: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 442 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 443 of 452

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State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

69. P140, Stamping Press 1-250

Operations, Property and/or Equipment Description:

Stamping Press to form metal products using lubricating oil; installed prior to 1970.

a) The following emissions unit terms and conditions are federally enforceable with the exception of those listed below which are enforceable under state law only.

(1) b)(1)d., and d)(3).

b) Applicable Emissions Limitations and/or Control Requirements

(1) The specific operations(s), property, and/or equipment that constitute each emissions unit along with the applicable rules and/or requirements and with the applicable emissions limitations and/or control measures. Emissions from each unit shall not exceed the listed limitations, and the listed control measures shall be specified in narrative form following the table.

Applicable Rules/Requirements Applicable Emissions Limitations/Control Measures

a. OAC rule 3745-31-05(D)(Synthetic Minor to avoid requirements of 40 CFR Part 63 Subpart MMMM)

The Hazardous Air Pollutants (HAPs), emissions from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs.

See Sections b)(2)c., d)(2), e)(1), and f)(1)c., below.

b. OAC rule 3745-31-05(F) The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140.

See Sections d)(1), e)(1), and f)(1)b., below.

c. OAC rule 3745-21-07(G) See Sections b)(2)a., b)(2)b., d)(4), e)(1), and f)(1)d., below.

d. OAC rule 3745-114-01 See Section d)(3), below.

(2) Additional Terms and Conditions

a. On February 18, 2008, OAC rule 3745-21-07 was revised to delete paragraph (G); therefore, paragraph (G) is no longer part of the State regulations. However, that rule revision has not been approved by the U.S.EPA as a revision to Ohio's State Implementation Plan (SIP). Therefore, until the SIP revision occurs to OAC rule 3745-21-07, the requirement of the previous OAC rule 3745-21-07(G) still exists as part of the federally approved SIP for Ohio.

Page 444 of 452

Page 453: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio's State Implementation Plan (SIP) is revised, the terms and conditions within this permit which are required by previous OAC rule 3745-21-07(G) will not be required and will not be federally and/or state enforceable.

Once the February 18, 2008, revised OAC rule 3745-21-07, or modified version of OAC rule 3745-21-07 is approved by the U.S. EPA and Ohio’s State Implementation Plan (SIP) is revised, the permittee shall take immediate steps to assure compliance with any and all requirements of the revised OAC rule and/or SIP.

b. The liquid organic materials employed by this emissions unit shall not be exposed to temperatures exceeding 220 degrees Fahrenheit, and the boiling points shall exceed 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure. Pursuant to OAC rule 3745-21-07(G)(9)(e), liquid organic materials which exhibit the aforementioned physical properties and are not exposed to temperatures exceeding 220 degrees Fahrenheit are not subject to the requirements of OAC rule 3745-21-07(G).

c. The actual usage of Hazardous Air Pollutants (HAPs), as identified in Section 112(b) of Title III of the Clean Air Act, from all non-insignificant emissions units at this facility shall not exceed 9.0 TPY* for any single HAP and 22.5 TPY* for any combination of HAPs. Compliance with the above limitations shall be based on a rolling, 12-month summation.

*This assumes the HAPs emitted are the same as the amount of HAPs used since all HAPs used evaporate.

c) Operational Restrictions

(1) VOC emissions from emissions units P107 through P114 and P117 through P140 combined shall not exceed 10.5 tons per rolling 12-month period. Emissions shall be calculated according to the following formula:

i10.5 tons (Gi)(Vi) 2000 lbs/ton

n=1Where

Gi = usage of lubricant i in gallons for the rolling 12-month period

Vi = VOC content of lubricant i in pounds of VOC per gallon, subject to the following limitation: Vi 5.75 lbs VOC/gallon

i = total number of unique lubricants used on emission units emissions units P107 through P114 and P117 through P140 combined.

d) Monitoring and/or Recordkeeping Requirements

Page 445 of 452

Page 454: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

(1) The permittee shall maintain monthly records of the following information for emissions units emissions units P107 through P114 and P117 through P140, combined:

a. the company name or identification for each lubricating oil with a VOC content greater than zero (0) employed;

b. whether or not each liquid organic materials employed have boiling points exceeding 200 degrees Fahrenheit at 0.5 millimeter mercury absolute pressure or the materials have been exposed to temperatures exceeding 220 degrees Fahrenheit;

c. the volume, in gallons, of each lubricating oil employed per rolling, 12-month summation;

d. the VOC content of each lubricating oil solvent employed, in pounds per gallon;

e. the rolling 12-month summation of VOC emissions from the lubricating oils employed, i.e., the sum of the usage of each lubricating oil employed multiplied by its respective VOC content.

(2) The permittee shall collect and record the following information each month for the HAP(s) employed in all non-insignificant emissions units at this facility:

a. the emission unit's source identification and description that Hazardous Air Pollutant (HAP) containing materials were employed;

b. the name and identification number of each HAP containing material employed;

c. the individual HAP* content for each HAP containing material employed, in pounds of individual HAP per gallon, as employed;

d. the amount of each HAP containing material employed, in gallons;

e. the total individual HAP usage for each HAP from the above listed materials employed, in pounds or tons per month [for each HAP the sum of (c) times (d)];

f. the total combined HAP usage from all above listed materials employed, in pounds or tons per month [the sum of (c) times (d) for each coating];

g. the updated rolling, 12-month summation of usage for each individual HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months; and

h. the updated rolling, 12-month summation of usage for total combined HAP**, in pounds or tons. This shall include the information for the current month and the preceding eleven calendar months.

* A listing of the HAPs can be found in Section 112(b) of the Clean Air Act or can be obtained by contacting your Ohio EPA, Southwest District Office contact. This information does not have to be kept on a line-by-line basis.

Page 446 of 452

Page 455: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

** This assumes the HAP(s) emitted are the same as the amounts of HAP(s) used since all HAP(s) used evaporate.

(3) Modeling to demonstrate compliance with, the AToxic Air Contaminant Statute@, ORC 3704.03(F)(4)(b), was not necessary because the emissions unit=s maximum annual emissions for each toxic air contaminant, as defined in OAC rule 3745-114-01, will be less than 1.0 ton per year. OAC Chapter 3745-31 requires permittees to apply for and obtain a new or modified permit to install prior to making a "modification" as defined by OAC rule 3745-31-01. The permittee is hereby advised that changes in the composition of the materials, or use of new materials, that would cause the emissions of any toxic air contaminant to increase to above 1.0 ton per year may require the permittee to apply for and obtain a new permit to install.

[ORC 3704.03(F)(3)(c) and F(4)]

(4) This facility shall maintain the following daily records if any material employed is by definition photo chemically reactive material "PRM" or contains a substance that is by definition "PRM", are used in this emissions unit:

a. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the amount of each "PRM" material or "PRM" containing material employed, in gallons;

b. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound content of each "PRM" material or "PRM" containing material employed, in lbs/gal;

c. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the organic compound (OC) emissions of each "PRM" material or "PRM" containing material employed, in lbs of OC/day ("a" x "b");

d. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the total number of hours this emission unit was operated, in hours/day; and

e. if any material employed is by definition "PRM" or contains a substance that is by definition "PRM", the estimated hourly OC emission rate, in lbs of OC/hr ("f"/"g").

e) Reporting Requirements

(1) The permittee shall submit quarterly deviation (excursion) reports that identify the following:

a. any monthly record showing noncompliance with the rolling, 12-month VOC emissions limit of 10.5 tons for emissions units emissions units P107 through P114 and P117 through P140, combined;

b. an identification of each month during which the individual HAP emissions from all non-insignificant emissions units at this facility exceeded 9.0 tons per year, based on a 12-month rolling average; and

Page 447 of 452

Page 456: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

c. an identification of each month during which the combined HAP emissions all non-insignificant emissions units at this facility exceeded 22.5 tons per year, based on a 12-month rolling average;

d. any monthly record showing noncompliance with the liquid organic material usage limitation for this emissions unit, i.e., liquid organic materials must not be exposed to temperatures exceeding 220 degrees Fahrenheit and the boiling points must exceed 200 degrees at 0.5 millimeter mercury absolute pressure per OAC rule 3745-21-07(G)(9)(e); and

e. any daily record when employing photo-chemically reactive materials that demonstrates organic compound (OC) emission of greater than 8 pounds per hour and/or 40 pounds per day.

The quarterly deviation (excursion) reports shall be submitted in accordance with the reporting requirements of the Standard Terms and Conditions of this permit.

[OAC rule 3745-15-03(B)(1)(a)] and [OAC rule 3745-15-03(C)] and [OAC rule 3745-77-07(C)(1)]

f) Testing Requirements

(1) Compliance with the emission limitations in b)(1). of these terms and conditions shall be determined in accordance with the following methods:

a. Emission Limitation:

The combined volatile organic compound (VOC) emissions shall not exceed 10.5 tons as a rolling, 12-month summation for emissions units P107 through P114 and P117 through P140, inclusive.

Applicable Compliance Method:

Compliance with the rolling, 12-month VOC emissions limitation shall be determined through the record keeping requirements established in d)(1) of this permit.

b. Emission Limitation:

Individual HAP emissions shall not exceed 9.0 tons and combined HAP(s) emissions shall not exceed 22.5 tons per rolling, 12-month period from all non-insignificant emissions units at this facility (for this emissions unit)

Applicable Compliance Method:

Compliance with the above HAP(s) emission limitations shall be demonstrated through the record keeping requirements established in Section d)(2) of this permit.

c. Compliance with the emission limitations specified by the SIP and the previous OAC rule 3745-21-07(G)(2) in section b) of these terms and conditions shall be determined in accordance with the following methods:

Page 448 of 452

Page 457: A.Standard Terms and Conditions  · Web viewin Microsoft Word and Adobe Acrobat format. If U.S. EPA does not object to this proposed permit, the permit will be processed for issuance

State of Ohio Environmental Protection AgencyDivision of Air Pollution Control

Proposed Title V PermitPermit Number: P0088868

Facility ID: 0575010106Effective Date: To be entered upon final issuance

Emission Limitations:

The OC emissions from the use photochemically reactive liquid organic materials or substance containing photochemically reactive material shall not exceed 8 pounds per hour nor 40 pounds per day.

Applicable Compliance Method:

Compliance with the above OC emission limitations shall be determined by the recordkeeping requirement specified in d)(4).

(2) Formulation data of or USEPA Method 24 shall be used to determine the VOC content of each lubricating oil material.

g) Miscellaneous Requirements.

(1) None.

Page 449 of 452